# ~rt.. 

# wAmeren Ameren Energy ReSDurces

R. Alan KBIIBY
President & Chief Executive Officer

December 27, 2007

Mr. Jim Ross, Manager

Division of Air Pollution Control

Bureau of Air

Illinois Enviromnental Protection Agency

1021 North Grand Avenue East

P. O. Box 19726 Springfield, II. 62794-9276

RE: Illinois Mercury Rule Multi-Pollutant Standard

- Notice oflntent

Dear Mr. Ross: One Arneren Plaza 1901 Chouteau Avenue PO Box 66149, MC 10 St. Louis, MO 63166-6149

314.554.2IUS

314.554.3086 fax rakel/ey@ameren.com



# RECEIVED

JAN 0 2 2008**!"'Cl~** !i1>I'I©ti'.

### ~!FfLij]**ll~~** i'\;,

... I.:JNlfl.iD 

## v

In accordance with 35 Illinois Administrative Code Part 225 Subpart B Section 225.233 (b), Ameren Energy Resources, as authorized agent for Ameren Energy Generating Company, AmerenEnergy

Resources Generating Company and Electric Energy Inc., submits this notice of intent that the owners of the following eligible electric generating units elect to demonstrate compliance with the multipollutant emission limitation as an alternative to the emission standards of Section 225.230. This
notice of intent is submitted for the following emission units that are eligible electric generating units (EGUs):

Ameren Energy Generating Company

Facilitv Facilitv I. D. Emission Unit

Coffeen 135803AAA 01

Coffeen 135803AAA 02

Hutsonville 03380lAAA 05

Hutsonville 03380lAAA 06

Meredosia 137805AAA 01

Meredosia 137805AAA 02

Meredosia 137805AAA 03

Meredosia 137805AAA 04

Meredosia 137805AAA 05

Newton 079808AAA 1

Newton 079808AAA 2

AmerenEnergy Resources Generating Company

Facility Facility 1. D. Emission Unit

Duck Creek 05780lAAA 1

E. D. Edwards 143805AAG 1

E. D. Edwards 143805AAG 2

E. D. Edwards 143805AAG 3Electric Energy, Inc.

Facility Facility I. D. Emission Unit
Joppa 127855AAC 1
Joppa 127855AAC 2 Joppa 127855AAC 3
Joppa 127855AAC 4
Joppa 127855AAC 5
Joppa 127855AAC 6

..

The electric generating units (EGUs) identified above are eligible to participate as an Multi-Pollutant

Standard Group for the purpose of demonstrating compliance with the requirements of35 Illinois

Administrative Code Part 225 Subpart B Section 225.233. This notice of intent includes the following

components as attachments to this submittal: the base emission rates for the EGUs and supporting data; a

summary of current pollution control equipment installed; and a sunnnary of additional pollution control equipment that will likely be installed to comply with the MPS.

The EGUs identified in this notice of intent have commenced commercial operation on or before December
31,2004 and constitute all affected EGUs that were oWned by the listed affiliates as of July 1, 2006.

I am authorized to make this submission on behalf of the owners and operators of the affected units for

which this submission is made. Please contact Steven Whitworth at (314) 554

- 4908 if you have any questions concerning this submittal or if additional information is required.

Sincerely,

# ~{{[t21

President, Ameren Energy Generating Company
President, ArnerenEnergy Resources Generating Company

Director and Chairman, Electric Energy, Inc.

SCW / AEGAERGEECMPSnotice

Attachments

## Ameren Energy Resources Company
Multi-Pollutant Standard Notice ofIntent
Attachment A 

## Summary of Existing Pollution Control Equipment

Ameren Energy Generating Company

Facilitv Facilitv I. D. Emission Unit Particulate Control NOx Control S02 Control
Coffeen 135803AAA 01 ESP OFAISCR
Coffeen 135803AAA 02 ESP OFAISCR
Hutsonville 03380lAAA 05 ESP
Hutsonville 033801AAA 06 ESP
Meredosia 137805AAA 01 ESP
Meredosia 137805AAA 02 ESP
Meredosia 137805AAA 03 ESP
Meredosia 137805AAA 04 ESP
Meredosia 137805AAA 05 ESP LNB

Newton 079808AAA I ESP OFAlLNB

Newton 079808AAA 2 ESP OFAlLNB

AmerenEnergy Resources Generating Company

Facijji-; Facijji-; I. D. Emission Unit Particulate Control NOx Control S02 Control
Duck Creek 05780lAAA I ESP LNB/SCR FGD

E. D. Edwards 143805AAG I ESP LNB

E. D. Edwards 143805AAG 2 ESP LNB
E. D. Edwards 143805AAG 3 ESP OFAlLNB/SCR

Electric Energy, Inc.

Facijji-; Facijji-;I. D. Emission Unit Particulate Control NOx Control S02 Control
Jonna 127855AAC I ESP

. LNB
JooDa I 27855AAC 2 ESP LNB J;;;;;;-a I 27855AAC 3 ESP LNB
Joooa I 27855AAC 4 ESP LNB
Jonna 127855AAC 5 ESP OFNLNB

Joooa 127855AAC 6 ESP OFAlLNB

## Ameren Energy Resources Company

Multi-Pollutant Standard Notice oflntent

Attachment B

Base Emission Rate Determination

### Ameren MP5 Base Annual Emission Rate Detennination

2003 Heat Input NOxRate NOx 502 Rate 502

Comnanv ImmBtu\ 1#/mmBtu\ Itonsl l#/mmBtu\ Itonsl

AEGC 158,452,698 0.259 20,527 1.14 90,117

AERGC 63,611,097 0.368 11,690 2.06 65,440

EEl 89,504,514 0.129 5,771 0.54 24,026

AER Illinois 311,568,309 0.244 37,988 1.15 179,583

2004 Heat Input NOxRate NOx 502 Rate 502

Comnan v ImmBtul l#/mmBtul Itonsl l#/mmBtul Itonsl

AEGC 171,427,867 0.249 20,710 1.06 90,532

AERGC 70,737,248 0.309 10,897 1.47 52,058

EEl 92,482,478 0.127 5,860 0.61 28,048

AER Illinois 334,647,593 0.224 37,467 1.02 170,638

2005 Heat Input NOxRate NOx 502 Rate 502

Comnan v ImmBtul 1#/mmBtul /tonsl 1#/mmBtul Itonsl

AEGC 160,864,003 0.253 18,494 1.04 83,905

AERGC 65,569,490 0.267 .8,619 1.22 39,999

EEl 86,505,712 0.128 5,524 0.60 25,963

AER Illinois 312,939,205 0.235 32,637 1.01 149,867

Annual Average Heat Input NOx Rate NOx 502 Rate 502
Comnanv ImmBtul l#/mmBtul Itonsl 1#/mmBtul Itonsl

AEGC 163,581,523 0.243 19,910 1.08 88,185

AERGC 66,639,278 0.312 10,402 1.58 52,499

EEl 89,497,568 0.128 5,718 0.58 26,012

AER illinois 319,718,369 0.225 36,031 1.04 166,696

MP5 Rates

NOx at 0.11 or 52% of base rate in 2012
502 at 0.33 or 44% of base rate in 2013
502 at 0.25 or 35% of base rate In 2015 % 

### of base rate

0.117 % 

### of base rate

0.46

0.36Ameren MPS Base Seasonal NOx Emission Rate Determination

2003 Heat Input NOx Rate NOx

ComDanv ImmBtu) (#lmmBtu\ Itons\

AEGC 71,819,229 0.159 5,706

AERGC 26,917,427 0.255 3,427

EEl 37,416,091 0.126 2,359

AER illinois 136,152,747 0.169 11,492

2004 Heat Input NOx Rate NOx Company ImmBtu\ l#lmmBtu\ (tons)

AEGC 72,205,935 0.153 5,508

AERGC 30,512,335 0.180 2,750

EEl 30,951,063 0.126 1,956

AER illinois 133,669,333 0.153 10,214

.

2005 Heat Input NOx Rate NOx

ComDanv (mmBtu) 1#/mmBtu\ Itons\

AEGC 77,068,042 0.146 5,614

AERGC 28,277,603 0.170 2,397

EEl 37,004,541 0.126 2,328

AER Illinois 142,350,186 0.147 10,339

Seasonal Average Heat Input NOx Rate NOx

ComDanv ImmBtu\ 1#/mmBtu\ Itons\

AEGC 73,697,735 0.152 5,609

AERGC 28,569,121 0.200 2,858

EEl 35,123,898 0.126 2,214

AER Illinois 137,390,755 0.155 10,682

MPS Rates

NOx at 0.11 or 80"/0 of base rate in 2012 "/0 of base rate

0.124

## Ameren Energy Resources Company
Multi-Pollutant Standard Notice ofIntent
Attachment C Summary of Likely 

## Future Pollution Control Equipment

Ameren Energy Generating Company

Facility Facility I. D. Emission Unit Mercurv Control NOxControl 802 Control
Coffeen 135803AAA 01 8CR/FGD OFAl8CR FGD
Coffeen 135803AAA 02 8CR/FGD OFAl8CR FGD
Hutsonville 03380lAAA 05 ACI 2013) OFAlLNB
Hutsonville 03380lAAA 06 ACI 2013) OFAlLNB
Meredosia 137805AAA 01 ACI 20\3)

Meredosia 137805AAA 02 ACI 2013)

Meredosia 137805AAA 03 ACI (2013

Meredosia 137805AAA 04 ACI (2013
Meredosia 137805AAA 05 ACI 2009 OFAlLNB

Newton 079808AAA I ACI 2009 OFAlLNB/8CR FGD

Newton 079808AAA 2 ACI 2009 OFAlLNB/8CR FGD

AmerenEnergy Resources Generating Company

Facilitv Facility I. D. Emission Unit Mercury Control NOx Control 802 Control
Duck Creek 05780lAAA I 8CR/FGD LNB/8CR FGD

E. D. Edwards 143805AAG I ACI (2009) OFAlLNB

E. D. Edwards 143805AAG 2 ACI (2009) OFAlLNB
E. D. Edwards 143805AAG 3 ACI (2009) OFAlLNB/SCR FGD

Electric Energy, Inc.

Facilitv Facility I. D. Emission Unit Mercury Control NOx Control 802 Control Joppa I 27855AAC I ACI (2009) OFAlLNB FGD

JODDa 127855AAC 2 ACI 2009) OFAlLNB FGD Joppa 127855AAC 3 ACI 2009

. OFAlLNB

JODDa 127855AAC 4 ACI 2009 OFAlLNB
JODDa 127855AAC 5 ACI 2009 OFAlLNB FGD Joppa 127855AAC 6 ACI (2009 OFAlLNB FGD

# .:..**,~** 

# " DVNEGV November 26,2007 Keith McFarland

Vice President

Midwest Fleet Operations 

# c:

Dynegy Generation

A Division of Dynegy Inc

3890 North Illinois Street

Swansea, Illinois 62:226



### Mr. Raymond Pilapil Manager Compliance & 

### Enforcement Section

Illinois EPA

Bureau of Air

PO Box 19276 Springfield, Illinois 62794-9276 

# RECEIVED

DEC 032007

Re: CAIR Rule

- 35 lAC 225

Notice oflntent to Participate in MPS Environmental Protection Agencv Bureau of Air STATE OF ILLINOIS



### Dear Mr. Pilapil:

Dynegy Midwest Generation, Inc. (DMG) is giving notice of its intent to elect its units in the

Multi-Pollutant Standards group as per Section 225.233 as its means of complying with Subpart

B of Part 225. The following information accompanies this notification:

1. The identification of each EGU that will be complying with this Subpart B by means of

the multi-pollutant standards contained in this Section, with evidence that the owner has

identified all EGUs that it owned in Illinois as of July 1,2006 and which commenced

commercial operation on or before December 31, 2004;

2. The Base Emission Rates for the EGUs, with copies of supporting data and calculations;

3. A summary of the current control devices installed and operating on each EGU and

identification of the additional control devices that will likely be neededto comply with

emission control requirements of this Section, including identification of each EGU in the

MPS group that will be addressed by subsection (c)(l)(B) of this Section, with

information showing that the eligibility criteria for this subsection (b) are satisfied.

This information is in the attachments to this letter. Attachment 1 lists all the units (EGUs)

owned by Dynegy Midwest Generation, Inc. that utilize coal in Illinois. All of the units were owned before July 1,2006 and began operation before December 31,2004. Attachment 2 lists

the Base Emission Rate for the EGUs (values from 2003, 2004 and 2005). Attachment 3 gives a table of the control devices currently installed and future installations. Future installations are indicated with a proposed date. EGUs addressed by subsection (c)(l)(B) are identified along

with gross generation and percentgeneration of the MPS group.

### This letter also serves as notice under 225.270 and 40CFR Part 75.61 that Hennepin (ORIS 892)

Unit 1 and Unit 2 are served and monitored by a common stack. Vermilion (ORIS 897) Unit 1

and Unit 2 are also served and monitored by a common stack.

"1 am authorized to make this submission on behalf of the owners and operators of the NOX Budget sources or NOX Budget units for which the submission is made. 

### 1 certify under penalty of

law that 

### 1 have personally examined, and am familiar with, the statements and information

submitted in this document and all its attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, 

### 1 certify that the statements and information

are to the best of my knowledge and belief true, accurate, and complete. 

### 1 am aware that there

are significant penalties for submitting false statements and information or omitting required

statements and information, including thepossibility of fine or imprisonment. "

Sincerely,

DYNEGY MIDWEST GENERATION, INC.

# ~~~

Keith A.

# McF~a~ Vice President

Midwest Fleet Operations

Attachments

### Attachment 1



### EGUs owned by Dynegy Midwest Generation, Inc. and elected for MPS

Station UnitID ORIS Date of Commercial Gross Generation 1 

### Operation (GMW)

Baldwin I 

### 889 7/13/70 624

Baldwin 2 889 5/21/73 629

Baldwin 3 889 6/20/75 629

Havana 9 891 6/22/78 487 Hennepin 1 892 6/1/53 81 Hennepin 2 892 5/14/59 240

Vermilion 1 897 5/19/55 84

Vermilion 2 897 5/25/56 113

Wood River £ 

### 4 898 6/1/54 105

Wood River 5 898 7/31/64 383

Total Generation 3375

1 

### Gross Generation as listed in the Consent Decree.

2 

### The Gross Generation for Wood River Unit for is less than 4% ofthe total Gross Generation for

the MPS group (225.233 (c)(1)(b»

### Attachment 2

Base Emission Rates and calculations

Ib/mmBtu Tons mmBtu


### 2003 2004 2005 2003 2004 2005 2003 2004 2005

Seasonal
NOx 0.209 0.102 0087 9704 3824 4360 92894369 74935571 99783984
Annual
NOx 0.261 0.215 0.096 28455 23281 10639 218427022 216363263 221703763
Annual
S02 0.583 0.562 0.491 63622 60806 54394 218427022 216363263 221703763



### Values taken from IEP A handout which indicates values obtained from USEP A Clean Air

Markets Division

A 

### verage Values

Proaram Averaae Rate Reduction Limit

Seasonal NOx 0.133 20% 0.106

Annual NOx 0.191 48% 0.099

Annual S02 P1 2013-2014 0.545 56% 0.240

Annual S02 P2 0.545 65% 0.191

### Attachment 3

Table of Control Devices

Station Unit ID ESP Fabric Filter SCR Spray Dryer ACI

Absorber

Baldwin 

### 1 X 

### 20U X 

### 20U 2009

Baldwin 

### 2 X 

### 2012 X 

### 2012 2009

Baldwin 3 X 

### 2010 2010 2009

Havana 

### 9 X 

### 2009 X 

### 2009

- 2010 2009 Hennepin 

### 1 X 

### 2008 2009 Hennepin 

### 2 X 

### 2008 2009

Vermilion 

### 1 X X X



### Vermilion 

### 2 X X X



### Wood River j 

### 4 X



### Wood River 5 X 

### 2009

X

= 

### Device currently installed

Fntnre installation indicated by date of anticipated operation.

3 

### Wood River Unit 4 (ORlS 898) is electing to use (c)(l)(b) of Subpart B of Part 225.233I\n EDiSON JN1'ERNATIONAL1ll Company

VIA FEDERAL EXPRESS



### December 27,2007

Mr. Dave Bloomberg Acting Manager Compliance and Enforcement
Division of Air Pollution Control (MC40)
Bureau of Air
Illinois Environmental Protection Agency

1021 N. Grand Avenue East


### P.O. Box 19276 Springfield, IL 

### 62794-9276

Subject: Midwest Generation CPS Notice of Intent

35 lAC 225.61 O(a-c)

Dear Mr. Bloomberg,

Pursuant to Section 225.610 of Title 35 of the Illinois Administrative Code, Midwest Generation, LLC 

### hereby submits notice of its election and intention that the electrical generating units ("EGUs") set forth on the attached Table A will comply with Section 225.230(a) (35 lAC 225.230(a)) by means of Subpart F: Combined Pollutant Standards (CPS) of Part 225. Information required by Section 225.610 is listed on the attached
Table A. This letter confirms that Table A includes all of the EGUs specified under Subpart F ·thlll Midwest Generation, LLC 

### owned or operated as of December 31, 2006
and which C{lmmenced commercial operation on or before December 31, 2004.

If you have any questions, please feel free to contact me or Bill Constantelos at (312)

583-6029.

Sincerely,

Guy Gorney,
Senior Vice President

cc: Bill Constantelos
Daniel D. McDevittTable A SUbpart F Boiler Permit Owned or operated in Current Pollution Control Devices Control devices that will likely Designation Number IL as of December 31, Installed and Operating be needed for each EGU to
2006, and which comply with emission control

commenced requirements of Subpart F

commercial operation

on or before

December 31,2004 (Yes or No)

Crawford 7* 7 031600AIN Yes Cold ESP, Low NOx Burners & Overfire Air FGDand SNCR

Crawford 8* 8 031600AIN Yes Cold ESP, Low NOx Burners & Overfire Air FGD and SNCR

Fisk 19* 19 031600AMI Yes Cold ESP, Low NOx Burners & Overfire Air FGD

Joliet 7 71 197809AAO Yes Cold ESP, Low NOx Burners & Overfire Air FGD

Joliet 7 72 197809AAO Yes Cold ESP, Low NOx Burners & Overfire Air FGD

Joliet 8 81 197809AAO Yes Cold ESP, Low NOx Burners & Overfire Air FGD

Joliet 8 82 197809AAO Yes Cold ESP, Low NOx Burners & Overfire Air FGD

Joliet 6 5 197809AAO Yes Cold ESP & NOx Overfire Air SNCR and Rich Reagent Iniection

Powerlon 5 51 179801AAA Yes Cold ESP & NOx Overfire Air FGD and SCR

Powerlon 5 52 179801AAA Yes Cold ESP & NOx Overfire Air FGD and SCR

Powerlon 6 61 179801AAA Yes Cold ESP & NOx Overfire Air FGD and SCR

Powerton 6 62 179801AAA Yes Cold ESP & NOx Overfire Air FGD and SCR Waukegan 6 17 097190AAC Yes Cold ESP & NOx Overfire Air Retired by December 31, 2007
WaukeQan 7* 7 097190AAC Yes Hot ESP, Low NOx Burners & Overfire Air FGD Waukeqan 8* 8 097190AAC Yes Cold ESP, Low NOx Burners & Overfire Air FGD

Will County 1 1 197810AAK Yes Cold ESP & NOx Overfire Air Retired by December 31,2010

Will County 2 2 197810AAK Yes Cold ESP & NOx Overfire Air Retired by December 31,2010

Will County 3 3 197810AAK Yes Hot ESP, Low NOx Burners & Overfire Air FGD

Will County 4 4 197810AAK Yes Cold ESP, Low NOx Burners & Overfire Air FGDand SNCR

* Unit has a retirement opllon 

### If controls are not Installed based on the schedule In CPS rule 

### •

### Illinois Environmental Protection Agency

Public Notice Order Form

Division: Air Permits

Ordered By: Bradley Frost Phone: 217/782

- 7027

Public Notice Number: 001

Newspaper or location where ad is to be placed: S tate Paper (Taylorville?)

Run Date(s): 10/27 /2010

Special Instructions:

Ad is to run as an ROP Display

- NOT as a legal notice

Please typeset and border ad copy. Ad Size: 2 x 5

Authorizing Name: Brad Frost Date: October 19 , 2010

### ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

Notice of Public Hearing for State Impl ementation Plan Submittal

t o Address Regional Haze

The Illinois Environmental Protection Agency (Illinois EPA) will hold a public hearing on

December 6 , 20 10

, at 1:30 p .m. in the Sangamo Room at the Illinois EPA’s Headquarters at 1021 N. Grand Ave. East, Springfield, Illinois.

The hearing will be held by the Illinois EPA Bureau of Air for the purpose of gathering public

comment s on a revision to the Illinois State Implementation Plan (SIP) to address the visibility protection requirements of Section 169A of the Federal Clean Air Act for Federal Class I areas

. 42 U.S.C. § 7491. The proposal will be submitted to the United States En vironmental Protection Agency for review and approval as a revision to the SIP. The Federal requirements are set forth under Title 40: Protection of Environment, Part 51

-- Requirements for Preparation, Adoption, and Submittal of Implementation Plans, Subpa rt P

-- Protection of Visibility, 40 CFR §§ 51.300

-- 51.309. Regional h aze is visibility impairment caused by the cumulative air pollutant emissions from numerous sources over a wide geographic area. Accordingly, t his proposal has been prepared to satisfy Il linois ’ obligation to develop a regional h aze SIP with measures necessary to make reasonable progress towards remedying visibility impairment in Federal Class I areas. Under 40 CFR § 51.308, the core requirements for the plan include reasonable progress g oals, calculations of baseline and natural visibility conditions, long

- term strategy for regional haze, monitoring strategy, and Best Available Retrofit Technology requirements for regional haze visibility impairment

.

Copies of the draft SIP su bmittal for regional haze may be viewed by the public prior to the hearing during regular business hours (Monday through Friday 8:30 a.m. until 4:30 p.m, except for State holidays ) at the Illinois EPA’s Headquarters at 1021 North Grand Avenue East, Springfield, Illin ois, as well as on Illinois EPA’s website at http://www.epa.state.il.us. No walk

in requests for copies of this material will be accommodated , unless advance notice is provided

. Requests and public inquiries should b e directed to D ean Studer, the Illinoi s EPA’s Hearing

O fficer, at the address below

.

The hearing will be held under the provisions of the Illinois EPA’s “Procedures for Information al and Quasi

- Legislative Public Hearings

, ” set forth at 35 Ill. Adm. Code 164 . Any questions about the hearing p rocedures, requests for copies of the hearing rules, or requests for special need interpreters should be directed to the address below. Requests for special needs interpreters must be made by November 17 , 20 10

.

Closure of the Hearing Record. The Hearing Record will close on January 5, 2011 . Comments need not be notarized, but must be postmarked by midnight January 5

, 2011 , and mailed to Dean
Studer

, Hearing Officer, Illinois EPA, 1021 North Grand Avenue East, P.O. Box 19276, Springfield, Illinois 627 94

- 927 6, telephone number 217/558

- 8280 or TDD 217/ 782

- 9143.

# Illinois Environmental Protection Agency

December 6, 2010

# • Visibility Modeling of BART-eligible
Sources

• Modeling Methodology

• Modeling Results



# • BART Controls in Illinois

• EGUs

• Non-EGUs

#  

# CALPUFF is the USEPA approved regulatory model for long range transport and visibility

 

# It provides for chemical transformation of SO2 and NO2

 

# It calculates light extinction coefficients, consistent with Federal guidance, to assess effects on visibility

# • SO2, NOx, and primary PM are listed by USEPA as

visibility impairing pollutants

• IEPA developed a list of BART eligible sources from 26 applicable categories



# • Modeling parameters for each stack were developed from the IEPA emissions inventory system.
Emissions used are based on maximum short-term
allowables

# n 9 

# M 

# u

#  

# Meteorological files were developed by LADCO from national scale 36 km grid MM5 model. Three years of meteorological data 

# (2002-04) are used in the modeling.

 

# Multiple receptors are placed in each of 16 Class I areas that are likely to be impacted by


# Illinois sources.

# la I Ar a 

# includ d in th A 

# mod ling

#  

# Illinois followed the BART modeling protocol developed by LADCO and the MRPO states 

# (dated March 21, 2006).

 

# Protocol addresses selection of models, development of model inputs, and processing 

# and interpretation of model outputs.

 

# LADCO modeling protocol was approved by
USEPA and FLMs.

#  

# Based on USEPA’s BART guidance, a source considered to be causing or contributing to visibility impairment:

“...if the 98 th 

# percentile daily change in visibility is greater than 0.5 deciviews (DV) as compared to natural conditions”.

 

# In plain English, if 22 or more exceedances of the 0.5 DV threshold occur in three years at any Class I area, or if 8 or more exceedances occur in any one year, the 

# BART-eligible unit(s) at the source is(are) subject to BART controls

# Source Name Days > 0.5 DV 

# 3 years Days > 0.5 DV 

# 1 year



# Ameren

– Coffeen 175 68

Dynegy

– Baldwin 151 57

Ameren

– Edwards 136 53

Dominion

– Kincaid 118 50

CWL&P 103 44

Midwest Gen

– Joliet 103 40

Midwest Gen

– Powerton 93 37

Ameren

– Duck Creek 39 17

Midwest Gen

– Will Cty 32 16

Dynegy

– Wood River 16 6

# Source Name Days > 0.5 DV 3 years Days > 0.5 DV 1 year



# ExxonMobil 84 35

CITGO 52 22

Lone Star 3 2
Chicago Carbon 2 1

US Steel 1 1


# Conoco Phillips 0 0

Marathon 0 0

Aventine 0 0
Pilkington 0 0

Big River Zinc 0 0

IL Cement 0 0

Carmeuse Lime 0 0


# Owens Brockway 0 0

Koppers 0 0

Equistar 0 0

#  

# Dominion Kincaid submitted modeling to

support their proposed BART control strategy

 

# Their modeling addressed the two closest Class I areas, Mingo NWR and Mammoth Cave



# NP 

# Modeling

– Dominion Kincaid

# Scenario Days > 0.5
DV 3 years Days > 0.5

DV 1 year

Mingo

– Base emissions 97 38

Presumptive BART 3 1

BART proposal 2 1

Mammoth Cave

- Base emissions 83 40



# Presumptive BART 4 2
BART proposal 4 2

# • Used LADCO modeling protocol

• Includes larger domain, more Class I



# areas

• Compared the proposal to



# presumptive BART

# Illinois Approach to BART

Control 

# R quir m nt

# • Eligible sources are subject- to -BART controls if shown to cause or contribute to visibility impairment



# • The only sources that were found to be subject- to

BART were coal fired power plants and two petroleum refineries



# • In most cases, measures that were previously agreed to were found to result in greater reductions
than BART

• In two cases, IEPA pursued agreements with subject- to -BART EGUs

#  

# Illinois EPA compared presumptive BART emission levels to existing emission reduction requirements and commitments for 

# the subject- to -BART EGUs in Illinois.

 

# In all cases, Illinois found emission reductions from existing commitments to be greater 

# than presumptive BART.

#  

# The Multi- Pollutant Standard (“MPS”) and Combined Pollutant Standard (“CPS”) in the 

# Illinois Mercury Rule apply to Ameren, Dynegy, and Midwest Generation

 

# A Memorandum of Understanding (“MOU”) 

# between the IEPA and Dominion Energy Services applies to Kincaid Generating Station

 

# A similar MOU between the IEPA and City

, 

# Water, Light and Power (CWLP)

#  

# The MPS and CPS affect the Coal-fired EGUs operated by Ameren, Dynegy, and Midwest
Generation.

 

# These three entities account for approximately 88% of Illinois’ coal -fired capacity.

 

# Emission standards were negotiated on a

case- by -case basis.

#  

# IEPA anticipates a reduction in SO2 emissions of approximately 214,600 tons per year by
2015.

 

# IEPA anticipates a reduction in NOx emissions of approximately 90,000 tons per year by
2015.

#  

# Both units at the Kincaid facility are subject to
BART controls.

 

# Dominion conducted a site-specific BART 

# analysis for the Kincaid plant, including a control technology review and CALPUFF modeling to assess the visibility impacts of


# several control alternatives.

#  

# Dominion agreed in the MOU to a very low NOx emission rate of 0.07 lbs/mmBTU by
2017.

 

# Presumptive BART for NOx is 0.10.

 

# The agreement requires an SO2 emission rate of 0.18 lbs/mmBTU by 2017.

 

# Presumptive BART for SO2 is 0.15.

 

# Modeling has shown that this alternate control plan will result in equivalent visibility 

# improvement at a much lower cost.

#  

# At the time of the MOU, CWLP was operating three BART eligible units: Dallman 31 and 32,
and Lakeside 8.

 

# The MOU includes an agreement to shut
down Lakeside 8.

 

# Presumptive BART for these units for NOx is 

# the operation of SCR.

 

# Presumptive BART for these units for SO2 is
95% control.

#  

# CWLP agreed in the MOU to meet an annual NOx emission rate of 0.12 lbs/mmBTU by 2015, and an annual rate of 0.11 lbs/mmBTU by 2017

 

# CWLP agreed in the MOU to meet an annual SO2 emission rate of 0.25 lbs/mmBTU by 2015, and an annual rate of 0.23 lbs/mmBTU by 2017.

 

# The calculated presumptive BART for SO2 of 95% 

# control is 0.30 lbs/mmBTU

 

# Illinois EPA estimates these reductions to be 5,375 tons of NOx per year and 4,875 tons of 

# SO2 per year in 2017.

# n fr

• 

# I • • 

# I I 

# in Illi x 

# U im 

# d N


# I fi 

# r

60,000

-.:=-- 

## 50,000

- 

### ro Q) 

### >..



# .... Q) 

## 40,000 0..

(/) c::: 

# g 30,000

- (/) c::: 0

(J) (/) 

## 20,000 "E



## w OX 

## 10,000 

## z

0 1--------------------1 

### 02002 Base Year



### • Presumptive

1--------------1 

### BART



### o2018CAIR

-Illinois 

## Requirements

MWGen Ameren Dynegy Dominion CWLP

# m

• 

# I 

# n fr • 

# I 

# I I I 

# i • 

# ml

• 

# In 2



# U • 

# Ir

180,000



## 160,000

...-



# .... 140,000 <1:1 (J)

>,



# .... 120,000 <]) 0..

(f) 

## 100,000 c 

# g

(f) 

## 80,000
c 0

ill 

## 60,000 (f) 

## 'E



## w 40,000

<'"' 

### 0 (f) 

## 20,000

0 02002 Base Year



## • Presumptive 

# BART

o2018CAIR

I--- 

## ---I-Illinois
R equ it-em ents

MWGen Ameren Dynegy Dominion CWLP

#  

# Both non-EGU sources in Illinois that are subject to BART control are petroleum
refineries.

 

# The CITGO refinery in Lemont is subject to a
Consent Decree finalized in 2004.

 

# The ExxonMobil refinery in Joliet is subject to


# a Consent Decree finalized in 2005.

#  

# Both refinery consent decrees result in large reductions of NOx, SO2, and PM emissions in Illinois.

 

# Factors considered in control requirements for 

# both consent decrees are very similar to those require for BART analyses.

 

# Emission reductions from Consent Decree requirements are greater than applying BART 

# control to subject- to -BART units at the refineries in both cases.

 

# Emission reductions from the Consent Decrees will occur a few years earlier than if required by 

# BART

##  

# Several sources in Illinois have been determined to be BART-eligible and are causing or contributing to visibility impairment in some federal Class I areas in the
eastern US.

 

# Illinois has promulgated or negotiated emissions control requirements for most subject- to -BART

sources.

 

# These requirements provide emissions reductions that are well beyond what would be anticipated from only applying BART controls on subject- to -BART units.

 

# Illinois’ control requirements will provide greater visibility improvements than would occur from application of BART controls on subject- to -BART units.

# Overview of Regional Haze in the Upper Midwest

Michael Koerber
Lake Michigan Air Directors Consortium

December 6, 2010

# Overview

• Background (CAA requirements)

• Conceptual Model of Haze



# • Technical Basis for Visibility-Related Analyses



# • Reasonable Progress Evaluation

• Summary

# Visibility Requirements

Section 169A of Clean Air Act Amendments of 1977 requires “as a national goal the prevention of any future, and the remedying of any existing, 

# impairment of visibility in Class I areas which impairment results from manmade air pollution.”



# EPA’s visibility regulations (July 1, 1999) require “reasonable progress” to achieving natural conditions by the year 2064

# ...... 

# ,_.



# __ .....**_.,~--** 

# ._-



# .-

'" 

# .- ._- .



# __ ... ( ")**._~** C>oNl
,_ ("'l



# -""

''''_fWl 

# ._""



# -



# - -_

.....



# .. 

# -

.. .- 

# ..... Map of 156 National Park and Wldemess Areas
Protected by EPA's Regional Haze Rule

# Isle Royale National Park, Michigan

# Chicago, Illinois

# CAA also requires....

Each implementation plan must contain measures necessary to make reasonable progress toward meeting the national visibility goal, including...

(1) a requirement that each major stationary source (in 

# existence in 1977, but not in operation before 1962) which may reasonably be anticipated to cause or contribute to any impairment of visibility in any Class I area shall procure, install, and operate ... the best available retrofit technology ...for controlling emissions ... for the purpose of eliminating or 

# reducing visibility impairment, and

(2) a long-term strategy for making reasonable progress toward meeting the national visibility goal.

# Process for Establishing BART

Emission Limitations

Step 1 : 

# States identify those sources which meet the definition of “BART

- eligible source”

Step 2 : 

# States determine whether such sources “emit any air pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility (in a Class I area)”

– A source which fits this description is “subject to BART”



# Step 3 : 

# For each source subject to BART, States 

# then identify the appropriate type and the level of control for reducing emissions

# Which sources are BART-eligible?

• Start- up Date: “in existence” on Aug 8, 1977, and “in operation” on or after Aug 8, 1962

• Source Category: One of 26 specified categories

• Emissions: Potential to emit > 250 TPY of any visibility impairing pollutant ( SO

x 

# , NO

x 

# , PM, VOC,



# NH 3 

# )

# Which BART-eligible sources are subject to BART?

• Option 1: Consider all BART-eligible sources are subject to BART

• Option 2: Consider exempting some or all BART-eligible sources from BART review

• Individual source attribution approach

• Model plant approach

• Cumulative modeling approach

# So, what did we do.....

• EGUs (State- by -State decision)

• USEPA BART Rulemaking (July 6, 2005): “CAIR achieves greater progress than BART and may be used by States as a BART substitute.”



# • Non-EGUs

• Individual source attribution approach: CALPUFF 

# modeling of SO2 and NOx emissions (LADCO modeling protocol)

• Model plant approach: Calculated Q/d values (Note: EPA criteria consistent with Q/d = 10)

• Cumulative modeling approach: CAMx modeling of VOC and PM emissions

# CALPUFF Individual Source Modeling

A source is “subject to BART” if it causes (>1.0 dv) or contributes (>0.5 dv) to visibility impairment in any Class I area Q/d=100 Q/d=8

# Long Term Strategy

States must set reasonable progress goals (10- year increments)

In determining reasonable progress, states shall 

# consider:

1. costs of compliance,

2. time necessary for compliance,

3. energy and non-air quality environmental impacts of 

# compliance,

4. remaining useful life of existing sources subject to such requirements

5. uniform rate of visibility improvement (needed to attain 

# natural visibility conditions by 2064) – i.e., “glide path”

# 20% best visibility days 

# 20% worst visibility days Baseline
Conditions

Baseline
Conditions Natural
Conditions 

# Visibility “Glide Paths”

# ...... 

# ,_.



# __ .....**_.,~--** 

# -**._~** C>oNl
,_ ("'l



# -""

''''_fWl 

# ._"" 

# ._-

._- 

# .- 

# .-

'"



# - -_

.....



# .. 

# -

.. .- 

# ..... Map of 156 National Park and Wldemess Areas
Protected by EPA's Regional Haze Rule

## 16

### September 20, 2007
Letter : “Kentucky

does not
find a need to request
additional
emission
reductions
from
Midwest

sources at
this time” July 30, 2007 Letter:

Included a “Statement”

that outlines the MANEVU States’ initial request for a course of action by states


### outside of the MANEVU region toward assuring reasonable progress at their Class I areas) September 18, 2007 Letter:
“Minnesota asks the five other significantly contributing states (IL, IA, MO, ND, and WI) to make
these same commitments
for further evaluation and implementation of

reasonable control
measures.”

Arkansas/Missouri: Held
several conference calls in spring/summer 2007. Apparently planning to

set RPGs based on existing controls.

## 18 

# Conceptual Model of Haze

## 19 

# Light Extinction (Visibility)

20% best days 20% worst days

## 20 

# Light Extinction (Visibility)

20% best days 20% worst days 2018 Emissions



# NOx

NH3

SO2

## 21 

# 20% Worst Visibility Days

– BOWA

## 22

## 23 

# Composite Back Trajectory: 20% Worst Visibility Days

## 24 

# Technical Basis for 

# Visibility-Related Analyses

## 25 

# Key Parameters

Baseline Conditions = Average visibility value for the 20% most (or least) impaired days for the period 2000- 2004

Natural Conditions = National visibility goal set 

# forth in section 169A (“prevention of any future and the remedying of any existing impairment of visibility... from man

- made air pollution”)

## 26



# Key Parameters

20% best visibility days 20% worst visibility days Baseline
Conditions

Baseline
Conditions Natural
Conditions

## 27

## 28 

# EPA Guidance Documents

## 29 

# http://vista.cira.colostate.edu/IMPROVE/ http://vista.cira.colostate.edu/views/

## 30 

# Reasonable Progress



# Evaluation

# Regional Air Quality Modeling

12 km



# 36 km Model: CAMx



# Domain/Grid: Eastern U.S. (36 km), Midwest (12 km)



# Year: 2002, 2005 (full year) - PM/haze, 36 km

2002, 2005 (summer)
- O 3 

# , 12 km

# Modeling Process

• Base Year Analysis (2002, 2005)

• Purpose: evaluate model performance



# • Future Year Analyses (2009, 2012, 2018)

• Purposes: assess candidate control measures and provide attainment demonstration

## 33

## 34

# Existing Control Programs

• On -Highway Mobile Sources

– Tier II/Low sulfur fuel

– Inspection/Maintenance programs (nonattainment areas)

– Reformulated gasoline (nonattainment areas)



# • Off-Highway Mobile Sources

– Federal control programs incorporated into NONROAD model (e.g., nonroad diesel rule), plus the evaporative Large Spark Ignition and Recreational Vehicle standards

– Heavy-duty diesel (2007) engine standard/Low sulfur fuel

– Federal railroad/locomotive standards



## – Federal commercial marine vessel engine standards



# • Power Plants

– Title IV (Phases I and II)

– NOx SIP Call

– Clean Air Interstate Rule



# • Other Point Sources

– VOC 2-, 4-, 7-, and 10-year MACT standards

– Combustion turbine MACT

– Industrial boiler/process heater/RICE MACT

– Miscellaneous consent decrees and settlement agreements



# • Area Sources

– Aerosol coatings (new rule)

– Architectural and industrial maintenance (AIM) coatings (amendments)

– Household and institutional consumer products (amendments)

– Portable fuel containers (Mobile Source Air Toxics rule)

# Regional Emissions (TPD)

VOC NOx SO2

# Voyageurs, MN



# Boundary Waters, MN

Isle Royale, MI Seney, MI

# Statutory Factors

• Cost of compliance

• Time required for compliance

• Energy and non-air quality environmental impacts

• Remaining useful life



# Strategies of Interest

•“On the books” measures

• Possible additional controls (sector-level)

• Possible additional controls (individual facilities)



# Geographic Areas of



# Interest

• 3-state region: MI, MN, WI

• 9-state region: MI, MN, WI, plus IA, IL, IN, MO, ND, SD

# Geographic Areas of Interest

## 40



# Summary

• CAA sets a very difficult goal with respect to visibility 

# impairment in federal Class I areas

• “prevention of any future, and the remedying of any existing impairment of visibility...from manmade air pollution”



# • Midwest States have consulted and worked with other 

# states, FLMs, and tribes to address visibility impairment

• Intra-regionally to address Class I areas in LADCO region

• Inter -regionally to address Class I areas outside LADCO region



# • Technical analyses were conducted to assess baseline 

# (current) and projected (future year) visibility levels

• Current levels well above natural conditions • Projected levels (through 2018) are close to “glide path” (uniform rate of progress), but are still above natural conditions



# • Continued progress needed to meet natural conditions goal1

1 STATE OF ILLINOIS

2 ENVIRONMENTAL PROTECTION AGENCY

3

4

5

6

7

8

9

10

11 PUBLIC HEARING FOR STATE

IMPLEMENTATION PLAN SUBMITTAL

12 TO AD DRESS REGIONAL HAZE

13 DECEMBER 6, 2010

14

15

16

17

18

19

20

21

22

23

242

1 I N D E X

2 PRESENTATIONS BY: PAGE

3 MR. KOERBER 11

4 MR. LEOPOLD 30

5 MR. DAVIS 36

6

QUESTIONS BY:

7

MR. ELV ERT 41

8

MR. DIERICX 43

9

10

11

E X H I B I T S

12

EXHIBIT DESCRIPTION PAGE

13 1 Notice of Public Hearing 10

14

2 Draft SIP 10

15

3 Draft Technical Support for BART 10

16

17 (Exhibits not attached.)

18

19

20

21

22

23

243

1 STATE OF ILLINOIS

2 ENVIRONMENTAL PROTECTION AGENCY

3

4 PUBLIC HEARING FOR STA TE

IMPLEMENTATION PLAN SUBMITTAL

5 TO ADDRESS REGIONAL HAZE

6

7

8

9

10

11

12

13

14

15 PUBLIC HEARING held, on the 6th day of

16 December, 2010, between the hours of 1:30 P.M. and

17 2:35 P.M. of that day, at the offices of Illinois

18 Environmental Pr otection Agency, 1021 North Grand

19 Avenue East, Sangamo Room, Springfield, Illinois

20 62702, before Robin A. Adams, a Registered

21 Professional Reporter, Certified Shorthand Reporter,

22 and a Notary Public within and for the State of

23 Illinois.

244

1 A P P E A R A N C E S

2 HEARING OFFICER:

3 Illinois Environmental Protection Agency

Mr. Dean Studer

4 1021 North Grand Avenue East

P.O. Box 19276

5 Springfield, Illinois 62702

217.558.8280 6 dean.studer@illinois.gov

7

FOR LADCO:

8

Mr. Michael Koerber

9 Executive Director

10

FOR IEPA:

11 Mr. Scott A. Leopold 12 Environmental Protection Specialist

13 Mr. Rory Davis Environmental Protection Engineer

14

Mr. Robert J. Kaleel 15 Manager, Air Quality Planning Section

16 Ms. Gina Roccaforte

Assistant Counsel

17

18

19
Court Reporter: 20 Robin A. Adams, RPR, CSR Midwest Litigation Services
21 Illinois CSR #084

- 002046 15 S. Old State Capitol Plaza 22 Springfield, Illinois 62701

217.522.2211

23 800.280.3376

245

1 (Hearing began at 1:32 P.M.)

2 HEARING OFFICER: We'll go ahead and get

3 started.

4 Good afternoon. My name is Dean Studer, and

5 I'm the Hearing Officer for the Illinois

6 Environmental Protection Agency, otherwise referred

7 to as Illinois EPA.

8 This hearing is being held for the purpose of

9 gathering public comment on the d raft State

10 Implementation Plan revision submittal related to the

11 visibility protection requirements for the federal

12 Class I areas contained in Section 169A of the

13 federal Clean Air Act (CAA), USC Section 7491.

14 Can you all hear me? Okay.

15 Under 40 CFR Section 51.308, the core

16 requirements for the plan include reasonable progress

17 goals, calculation of baseline and natural visibility

18 conditions, a long

- term strategy for regional haze, a

19 monitoring strategy, and best available retrofit

20 technology

-- otherwise referred to as BART

--

21 re quirements for certain stationary emissions sources

22 to address the regional haze visibility impairment.

23 Regional haze is visibility impairment caused by

24 cumulative air pollutant emissions from numerous6

1 sources over a wide geographic area.

2 The Illinois EPA plans to submit this

3 proposal to the Unite d States Environmental

4 Protection Agency (USEPA) for review and approval as

5 a revision to the State Implementation Plan,

6 otherwise referred to as SIP, S

- I

- P. Copies of the

7 draft SIP p roposal are available on the Illinois EPA

8 website at www.epa.state.il.us/air.

9 This hearing is being held under the

10 provisions of 35 Illinois Administrative Code 164,

11 Procedures for Informational and Quasi

- Legislative

12 Public Hearings. Copies of these procedures can be

13 accessed on the website for the Illinois Pollution

14 Control Board at www.ipcb.state.il.us, or if you do

15 not have ready access to the web, they can be

16 obtained from me upon request.

17 I will introduce the Illinois EPA staff

18 members present today. This will be followed by

19 presentations from IEPA staff members Scott Leopold

20 and Rory Davis and Mike Koerber from LADCO.

21 Following this, I will allow the public to ask

22 questions or provide comments and ask questions. You

23 are not required to verbalize your comments as

24 written comments are given the same consideration and7

1 may be submitted to the agency at any time within the

2 public comment period which ends just before midnight

3 on January 5, 2011. Any person who wants to make

4 oral comments may do so as long as the statements are

5 relevant to the issues at hand and such person has

6 indicated on the registration card that he or she

7 would like to comment. If you have lengthy comments

8 or questions, it would be helpful to submit them to

9 me in writing before the close of the comment period,

10 and I will ensure that they are included in the

11 hearing as

-- the hearing record as exhibits.

12 Pl ease keep your comments and questions

13 relevant to the issues at hand. If your comments

14 fall outside the scope of this hearing, I may ask you

15 to proceed to another issue. Remember, all written

16 comments, whether or not you say them aloud, will

17 become part of the official hearing record and will

18 be considered. The registration cards are on the

19 table up front by the door when you walk ed in. If

20 you have not filled out a card or have not signed in,

21 please do so at this time. And if you fill out a

22 card, you can indicate if you would like to speak

23 this afternoon. An yone who completes a registration

24 card or files written comments in this matter will8

1 also be notified of the Illinois EPA' s final decision

2 in this matter. That notification will also contain

3 information as to how you may access the agency

4 responsiveness summary. In this summary, Illinois

5 EPA staff will attempt to answer all the relevant and

6 significant questions raised at the hearing or

7 submitted to me prior to the close of the comment

8 period.

9 Again, the written record in thi s matter will

10 close just before midnight on January 5, 2011.

11 Therefore, I will accept written comments as long as

12 they are postmarked on or before January 5. During

13 the comment period , all relevant comments, documents,

14 or data will also be placed into the hearing record

15 as exhibits. Please send all written documents or

16 data to me at the following address: And that's Dean

17 Studer, D

- e

- a

- n S

- t

- u

- d

- e

- r, Hearing Officer, Office

18 of Community Relations, regarding regional haze and

19 BART SIP, Illinois Environmental Protection Agency,

20 1021 North Grand Avenue East, Post O ffice Box 19276,

21 Springfield, Illinois 62794

- 9276. This address is

22 also listed on the public notice for the hearing this

23 afternoon.

24 And for anyone wishing to make comments or9

1 ask questions, I'd like to inform you that there is a

2 court reporter here taking a verbatim record of these

3 proceedings for the purpose of making our

4 administrative record. For the benefit of the court

5 reporter, please keep the general background noise in

6 this room to a minimum so she can hear everything

7 that is said. Also, when you begin to speak, please

8 state your name. And also, to make sure that it's

9 properly reflected in the record, if you are

10 representing any governmental body , organization, or

11 association, I ask that you identify that after your

12 name. Also for the benefit of the court reporter,

13 please spell your last name. If there are alternate

14 spelling s of your first name, you may spell that as

15 well.

16 When your name is called, please come forward

17 to the podium and state your name. If you are

18 representing any governmental bod y, organization, or

19 association, as I said, please indicate. For the

20 initial round of comments, I will limit each speaker

21 to ten minutes. At the end of ten minutes, I'll

22 bring the ne xt person forward. If we have time,

23 after I have called forward those that have indicated

24 their desire to speak, then I will allow anyone else10

1 who has not yet spoken the opportunity to speak. If

2 time allows, then I will allow those who initially

3 ran out of time to come forward and speak again.

4 A nd before we start with the Illinois EPA

5 presentations, I'd like to record a few preliminary

6 documents into the record as exhibits. For the

7 record, Exhibit No. 1 is a copy of the notice of the

8 public hearing. Exhibit 2 is the draft SIP document,

9 including its attachments. This draft document is

10 called Draft Regional Haze State Implementation Plan

11 for Illinois, and it's dated Octob er 7, 2010.

12 Exhibit 3 is the draft technical support document for

13 BART, including its attachments. This draft document

14 is called Draft Technical Support Document for Best

15 Available Re trofit Technology Under the Regional Haze

16 Rule, and it is dated September 30, 2010. Both of

17 these documents, including their attachments, are

18 available on the agency's web page.

19 Are there any questions at this point on how

20 I'm going to proceed?

21 Okay. With that, I will turn things over to

22 Mike for the first

-- first presentation, and if you

23 would in troduce yourself and

--

24 MR. KOERBER: Sure. My name is Michael11

1 Koerber. I'm the executive director for the Lake

2 Michigan Air Directors Consortium or LADCO.

3 I will be giving an overview of the regional

4 haze program. I'll start off talking about the

5 regulatory requirements, and we'll actu ally spend

6 quite a bit of time going over those requirements.

7 And then I'll be discussing several different issues

8 that were touched on in the opening remarks and will

9 be covered more here today: a conceptual model of

10 haze; what do we know about regional haze in the

11 Midwest; the technical basis for doing

12 visibility

- related analyses; terms like baseline

13 concentratio n and natural conditions

-- I'll be

14 talking about those; and then finally the reasonable

15 progress evaluation which is a key part of the

16 states' long

- term strategy.

17 So our funda mental requirement in terms of

18 addressing visibility under the Clean Air Act comes

19 from Section 169A, and what we have here is really

20 the toughest air quality challenge of all. We have

21 National Ambient Air Quality Standards, as you're

22 probably aware, for criteria pollutants. Here, in

23 the case of visibility, we don't have a standard but

24 we have a goal. And what we have under the Cl ean Air12

1 Act is a goal of preventing any future and remedying

2 any existing impairment of visibility in Class I

3 areas

-- I'll say more about those in just a

4 minute

-- resulting from manmade air pollution. So,

5 in a sense, this is a no manmade air pollution goal.

6 To implement this provision of the Cl ean Air

7 Act, EPA in 1999 adopted visibility regulations, and

8 the requirement

-- fundamental requirement under

9 those regulations is for states to require reasonable

10 progress towards ach ieving nature conditions

-- i.e.,

11 no manmade air pollution conditions

-- by the year

12 2064. So we're given a long period of time under

13 EPA's regulations to meet this Clean Air Act goal.

14 The Class I areas

-- there are 156 of the

15 larger parks and wilderness areas. Those are shown

16 here on this particular slide. As you can see, a lot

17 of these are out West. There are a handful in the

18 Midwest

-- or in the Eastern U.S., I should say. In

19 particular, I'll be saying quite a bit about the

20 Class I areas in northern Michigan and northern

21 Minnesota, the four in the northern part of the upper

22 Midwest. That's been the primary focus of the work

23 that we've done at LADCO in working with our states.

24 One of those Class I areas is Isle Royale13

1 National Park in Lake Superior. This slide just

2 shows what visibility looks like in Isle Royale on a

3 good visibility day on the left and a poor visibility

4 day on the right.

5 So while our focus is on visibility

6 impairment in these Class I areas, urban areas also

7 suffer from impaired visibility. It's not the direct

8 focus of this program. As I said, the focus of the

9 program is on the Class I areas. But, nonetheless,

10 we have visibility issues in urban areas, and that's

11 addressed t hrough other provisions of the Clean Air

12 Act and other air quality standards.

13 The Clean Air Act goes on to talk about the

14 implementation plans that the states must develop to

15 a ddress this particular problem. And the two

16 fundamental provisions I'm going to be talking about

17 over the next couple of minutes deal with BART, best

18 available retrofit technology, which applies to a

19 select group of existing facilities, and the

20 long

- term strategy

-- really the heart of the states'

21 program

-- that's to provide for reasonable progress

22 to meet our natural conditions go al.

23 So starting with BART, there's a three

- step

24 process, and EPA has actually established another14

1 regulation which deals with setting BART emission

2 limitations. First step is to define sources which

3 are BART eligible. I'll say more about that in just

4 a minute. The second step, once you've ident ified

5 the BART

- eligible source, is to determine which of

6 those actually are a problem with respect to

7 visibility impairment. That subset of sources is

8 referred to as those that are su bject to BART. And

9 then the third step is, for those sources that are

10 subject to BART, to actually conduct an engineering

11 analysis to set the BART emission limitation. So I'm

12 going t o talk about each one of these over the next

13 couple of slides.

14 In terms of identifying which sources are

15 BART eligible, there are three criteria: the

16 start

- up date, the source category, and the level of

17 emissions. And you can see the particular criteria

18 identified on this particular slide.

19 Once that list of BART

- eligible sources is

20 identified, the next step is to determine which of

21 those is actually subject to BART. Under EPA's

22 regulation, there are a couple of options that are

23 discussed. One is to just assume that all

24 BART

- el igible sources are subject to BART, and I15

1 believe some states have opted into that particular

2 option. The second is to co nsider exempting some or

3 all of those sources from BART review, and there are

4 several approaches laid out in EPA's regulation.

5 There's an individual source analysis, there's a

6 model pl ant approach in which you assume a number of

7 facilities are represented by a particular plant

8 type, and the third is a cumulative modeling approach

9 in which all of the emissions for a particular

10 pollutant are modeled together.

11 So in the Midwest, in terms of looking at the

12 existing point source inventory, we look at electric

13 generating units, EGUs, and the other part of the

14 point source inventory are referred to as non

- EGUs.

15 For EGUs, we have, as part of EPA's BART

16 rulemaking, a statement that their

-- EPA's Clean Air

17 Interstate Rule or CAIR achieve s greater progress

18 than BART and may be used by some states as a BART

19 substitute, and many states have relied on that to

20 meet the EGU BART requirement.

21 With respect to the non

- EGUs, again, the

22 three approaches that could be taken, one is some

23 indiv

-- is to do individual source modeling, and the

24 tool that's identified as CALPUFF to do that16

1 modeling, with a focus on the SO2 and NOx emissions.

2 And LADCO worked with the states to identify an

3 approach, a modeling protocol, that sho uld be

4 followed by everybody so we have a consistent

5 approach in doing that individual source modeling.

6 The other two approaches got a little bit of

7 attention, but most of the effort that LADCO worked

8 with the states on was on the individual source

9 modeling.

10 Just some example results from that CALPUFF

11 individual source modeling. These happen to be

12 facilities in another state, but they give us a sense

13 of what the impact is of these given facilities on

14 visibility levels downwind. And under EPA's

15 regulation, a source is assumed to be subject to BART

16 if it causes or contributes to visibility impairment

17 in any Class I area, and the specific levels to

18 qualify as causing or contributing are identified on

19 this partic ular slide.

20 And, Scott, you're going to be going into

21 that in more detail, I assume, in your remarks?

22 MR. LEOPOLD: Yes.

23 MR. KOERBER: Okay. So that's as much as I

24 really wanted to say about BART.17

1 Like to move on and talk about the other

2 provision that's required of the State Implementation

3 Plan, and that's the long

- term strategy. The main

4 goal of the long

- term strategy is to define the

5 reasonable progress goal. As I said before, under

6 EPA's regulation, we have 60 years to achieve this

7 natural conditions goal under the Clean Air Act.

8 And in determining what is reasonable

9 progress, there are five factors that are to be

10 considered: There's the cost of compliance, the

11 time necessary for compliance, energy and non

- air

12 quality environmental impacts of compliance,

13 remaining useful life of existing sources sub ject to

14 such requirements

-- those four requirements are

15 actually spelled out in the Clean Air Act

-- and then

16 in EPA's visibility rule, there was a fifth criteria

17 that was identified, and that's the uniform rate of

18 visibility improvement needed to attain natural

19 conditions by the year 2064, the so

- called "glide

20 path." And here's a graphical depiction of that

21 glide path, and I'll be talking more about these

22 terms "baseline conditions" and "natural conditions"

23 in just a minute.

24 But the fundamental provision under EPA's18

1 visibility rule is to provide for improvement in

2 visibility for the 20 percent worst visibility days.

3 Those are one set of days that are sing led out in

4 EPA's regulation. And so you can see that the top

5 series of lines that are angling down from our

6 baseline conditions, which is our starting point,

7 what current visibility l evels are like

-- and

8 this is an example for those four northern Class I

9 areas

-- reaching to the lower, on the right

- hand

10 side, natural conditions. And on this time series,

11 that's th e year 2064; again, the time period provided

12 for under EPA's visibility rule. So, again, we want

13 to improve visibility on the 20 percent worst days.

14 With respect to the 20 percent best

15 visibility days, the requirement is to ensure no

16 degradation, which is why that line is flat. We

17 don't want things to get worse on the 20 percent best

18 days.

19 So I'm g oing to be focusing, as I said a

20 couple of times, on the northern Class I areas in

21 northern Michigan and northern Minnesota. But at the

22 same time I want to make people aware that there was

23 a fair amount of consultation. We did not do this

24 work in isolation. While LADCO worked with its five19

1 member state s, we worked very closely with other

2 regional organizations across the United States: the

3 central states, Minnesota down through Texas; the

4 northeastern states; the southeastern states. We all

5 worked together very closely to coordinate the

6 technical work that we needed to do to look at Class

7 I areas within our regions. And as a result of that

8 technical process, there was also some policy

9 coordination between the groups. "Consultation" was

10 a specific term that we used. We wanted to consult

11 on development of control strategies and the

12 definition of reasonable p rogress goals for our

13 respective Class I areas.

14 So with respect to the northern Class I

15 areas, Minnesota in particular sent a letter to other

16 states a few years ago identifying what they thought

17 the needs were of their

-- of upland states on

18 setting the reasonable progress goals for the

19 northern Class I areas in Minnesota. Similarly there

20 was a letter sent out on behalf of Arkansas and

21 Minnesota

-- or discussions held on behalf of

22 Arkansas and Minnesota. Kentucky sent a letter, and

23 the northeastern states sent a letter. So not only

24 did we have technical coordination, there were also20

1 policy discussions among these various groups in

2 trying to develop reason able progress goals for the

3 Class I areas.

4 So that provides just a very brief overview

5 of the regulatory requirements that we're dealing

6 with here. I'd like to move on and tal k a little bit

7 about what we know concerning regional haze

8 specifically in these northern Class I areas.

9 Visibility is caused by fine particles in the

10 atmosphere. This particu lar bar graph depicts the

11 light extinction or pollution levels, if you will, on

12 the 20 percent best days in the four northern Class I

13 areas on the left

- hand side, versus the pollution

14 levels for the 20 percent worst days in these same

15 four northern Class I areas. And the higher bars

16 that you can see associated with the 20 percent worst

17 days represent higher pollution levels. So hig her

18 particle concentrations in the atmosphere lead to

19 higher impaired visibility, greater pollut

-- greater

20 visibility impairment.

21 Knowing what the specific chemical

22 composition is of these fine particles helps us in

23 terms of source identification, and we can do this

24 through a number of different approaches: either by21

1 looking at the monitoring concentration and working

2 backwards or starting with the emissions and working

3 towards the concentrations. So we've been able to

4 target certain source types as being key contributors

5 to visibility levels associated with the particular

6 chemical types, and that's what's depicted on this

7 slide.

8 Each of these sets of lines here or graphs

9 represents a different calendar year, starting with

10 2000 on the top and going down to 2004 at the bottom.

11 And each bar represents one of the 20 percent worst

12 visibility days in that particular year. These

13 happen to be results for boundary waters in northern

14 Minnesota, one of the Class I areas in northern

15 Minnesota. And the point here is t hat the 20 percent

16 worst visibility days really occur throughout the

17 year. They aren't confined to the winter or the

18 summer. They can occur in any season.

19 And it's a little d ifficult to see here, but

20 the stacked bars, again, represent the chemical

21 composition of the fine particles in the atmosphere.

22 It's a little bit easier to see here. For all four

23 of th e northern Class I areas, we've averaged the

24 results together by month. So we have January,22

1 February, all the way through December for each

2 individual Class I area. And the basic message here

3 is that during the beginning and the end of the year,

4 during the cooler months, you see a lot of red, which

5 repr esents ammonium nitrate in the atmosphere. In

6 the summer, you see a lot of yellow, which is

7 ammonium sulphate, and you also see a fair amount of

8 organic carbon in the summertime. So different times

9 of the year we have different chemical species. As I

10 said before, different species are associated with

11 different source types.

12 So it's really a fairly complex problem given

13 that we have these worst

- case conditions occurring

14 throughout the year. At different times of the year

15 it's different chemicals that are responsible for the

16 particulate loading in the at mosphere, and that each

17 of these different chemical types is associated with

18 different source types.

19 One more thing worth noting about our

20 conceptual model is where is the air coming from on

21 our poor pollution days. These are composite

22 trajectories for the northern Class I area. The

23 orange areas are those areas that are most likely

24 upwind on poor visibilit y days, and the green areas23

1 are the areas that are least likely upwind on the

2 poor visibility days. So you get a sense th at the

3 air is primarily out of the south or southwest when

4 we have poor visibility in these northern Class I

5 areas.

6 The other thing to note is that the darker

7 shading represents higher frequency. So that there

8 are some areas that are most likely to be upwind on

9 the higher visibility days

-- poor visibility days.

10 I'm going to talk now about the metri cs that

11 are important to implementing the visibility rule,

12 and there are two key parameters: One, baseline

13 conditions represent our starting point. What is the

14 current visibility in the air, and where do we need

15 to come from. So baseline conditions are a starting

16 point. The natural conditions are the goal. That's

17 what we need to achieve under the Clean Air Act to

18 represent these no manmade air pollution conditions.

19 And, again, these are depicted here on this

20 glide path diagram that I used earlier where, again,

21 the baseline conditions are on the left

- h and side,

22 the natural conditions are on the right

- hand side.

23 As I said before, the goal with respect to the 20

24 percent worst days is to improve visibility. The24

1 goal for the 20 percent best visibility days is to

2 ensure no degradation.

3 The data that we use to look at compliance

4 wi th these requirements primarily comes from a

5 monitoring network referred to as IMPROVE. I'm not

6 sure exactly what the acronym stands for. As you can

7 see, we have a fairly good network that's

8 representative of the Class I areas across the United

9 States, and we do have monitoring coverage in the

10 northern part of our domain which is where we have

11 our northern Class I areas.

12 In terms of applying the metrics, developing

13 the metrics, we have guidance from EPA on how to do

14 that, and the data is contained in a couple of

-- on

15 a couple of websites. There's an IM PROVE website,

16 and there's VIEWS website. These are two fundamental

17 databases where the public can go and access

18 information on what the visibility conditions are.

19 So the last part of my talk is going to talk

20 about the reasonable progress goals, which, as I said

21 before, is a fundamental element of the long

- term

22 strategy. We rely very heavily on air quality models

23 to evaluate candidate control programs and help in

24 setting reasonable progress goals. This particular25

1 slide summa rizes the regional modeling that LADCO has

2 worked with its states on. So you get a sense of

3 what the model is, the geographic scope of the

4 modeling analysis, and the years that we looked at.

5 And there are actually two base years we did

6 some modeling for: '02, 2002, and 2005. Two basic

7 steps in the modeling process: One is a base

- year

8 analysis in which we compare our model ed values for

9 that year with actual observations. The goal there

10 is to evaluate model performance. The next step is

11 to conduct future

- year analyses. We looked at three

12 future years to help states not only with their

13 regional haze planning but also some of the ozone and

14 fine particle work that they're also developing

15 implementation plans for. So the modeling, in a

16 sense, was really multi

- pollutant. Again, the focus

17 of today is more the regional haze work that was

18 done.

19 Looking at model performance, these are

20 results for boundary water s; the next slide for

21 Seney, one of the northern Class I areas in Michigan.

22 We've broken out the chemicals into the four

23 different quadrants here. We have nitrate in the

24 upper left

- ha nd corner, sulfate in the upper right,26

1 elemental carbon on the lower left, and the organic

2 carbon on the lower right. The red dots represent

3 the actual monitored values, and then the blue line

4 represents the modeled values. These are time series

5 plots throughout the calendar year, starting with

6 January 1 through December 31. And I think you get a

7 sense that for most of the chemical species, except

8 for organic carbon in the lower right

- hand corner,

9 the modeling is tracing the observed values fairly

10 closely. For organic carbon, especially in the

11 summertime, you see a lot of red dots well above the

12 blue line. We are underpredicting for that

13 particular chemical species. But for sul fates and

14 nitrates, the two represented at the top, the model

15 is doing a pretty good job of representing what was

16 actually observed.

17 The future

- year modeling relies on existing

18 control programs, and we really have a fairly long

19 list of control programs adopted at the federal level

20 and adopted by state governments to look at all

21 sectors of our emissions inven tory: on

- road sources,

22 off

- road sources, point sources, as well as area

23 sources. A lot of existing control programs, as many

24 people know, have gotten us a lot of emission27

1 reductions up until now. Many of those programs will

2 continue to provide further benefits as we look into

3 the future.

4 And that reduction in emissions is

5 represented here. We see for some of the main

6 precursor pollutants for regional haze

-- we have

7 volatile organ compounds on the left; oxides of

8 nitrogen, NOx, in the middle; and then SO2 on the

9 right

-- you see these bars getting shorter as you go

10 forward in time. Again, that's the result of

11 implementation

-- assumed implementation of these

12 existing control programs and the additional benefit

13 that we're going to get in air quality as we carry

14 these programs into the future.

15 So trying to represent the modelin g in the

16 context of the regional haze rule, the glide path

17 diagrams, I think, are fairly useful. Here we show,

18 for the four northern Class I areas, the baseline

19 conditions. So those dots on the left

- hand side

20 represent where we're starting from, with the line on

21 the top representing the 20 percent worst visibility

22 days, the line on the bottom in each diagram

23 repre senting the 20 percent best visibility days, and

24 then the dots on the far right

- hand side of each28

1 diagram representing the natural conditions goal for

2 the 20 percent worst and 20 percent best days.

3 The modeled values, looking at the future

4 years we've looked at

-- 2009, 2012, and 2018

-- are

5 repre sented by additional dots on this diagram as you

6 move forward in the time series. And the take

- home

7 message here is that we're pretty close to being on

8 the glide path, achieving a fairly uniform rate o f

9 progress through implementation of these control

10 programs. So meeting that particular goal and

11 setting our reasonable progress goal, I think the

12 modeling results show that we're doi ng a pretty good

13 job of doing so.

14 But there are four other goals that states

15 need to pay attention to in setting their reasonable

16 progress goals. We had a contractor evaluate these

17 goals. Looking at the northern Class I areas, they

18 issued a report a few years ago that's represented

19 here on the left

- hand side, and on the right

- hand

20 side of this slide, it pr ovides a little more detail

21 about the analysis. And while the focus was on

22 the northern Class I areas and those three states

23 that are the closest

-- Wisconsin, Michigan, and

24 Minnesota

-- we also looked at a number of other29

1 nearby states, including Illinois, as part of that

2 reasonable progress evaluation. So all that

3 information is documented in that particular report.

4 So let me wrap up by saying that what we have

5 in terms of a regulatory requirement is a very tough,

6 very diff icult goal under the

-- under Section 169A

7 of the Clean Air Act: preventing any future and

8 remedying any existing impairment of visibility from

9 manmade air pollution.

10 The stat es in the Midwest, through LADCO,

11 have worked together to address Class I areas within

12 our region. We've worked with downwind regions to

13 look at Class I areas outside of our region, and

14 we've done this on both the technical level and the

15 policy level. We, in particular, conducted technical

16 work to look at current conditions, so

- called

17 baseline levels, as well as future

- year conditi ons

18 looking at projected visibility levels. Clearly what

19 we see is that the current levels are above natural

20 conditions.

21 The good news is that the projected levels,

22 through adoption and implementation of existing

23 control programs, will keep us close to the glide

24 path, achieving a uniform rate of progress in30

1 improving visibility. But clearly continued progress

2 is necessary. We have not yet achieved natural

3 conditions. We have additional time under EPA's

4 pro gram to do so. This is a good step along the path

5 of what we need to do, but additional work will be

6 necessary.

7 So that concludes my remarks.

8 HEARING OFFICER: Thank y ou, Mr. Koerber.

9 We'll go ahead and do the other presentation

10 before we open the floor for questions this

11 afternoon.

12 Scott and Rory, if you'd like to introduce

13 yourselves and then proceed.

14 MR. LEOPOLD: I need a moment to bring up the

15 presentation.

16 My name is Scott Leopold. I am an air

17 quality modeler here at IEPA, and I will be doing the

18 first part of this presentation, and then Rory Davis

19 from our staff will be taking care of the second

20 part. What we will be doing is providing a little

21 more de tail about the best available retrofit

22 technology process.

23 There are really two parts to this process.

24 The first part was identifying and modeling the31

1 BART

- eligible sources, and the second part is

2 determining the appropriate BART controls in Illinois

3 for both EGUs and non

- EGUs. And I will be

-- a s I

4 said, I will be discussing the first part and Rory

5 will be taking care of the second part.

6 In visibility modeling, CALPUFF is the

7 approved regulatory model. It provides fo r chemical

8 transformation of sulfur dioxides and oxides of

9 nitrogen which are converted to sulfates and

10 nitrates, and we use this model because it has the

11 light extinction coefficients that are consistent

12 with federal guidance for the assessment of the

13 effects on visibility.

14 The initial step of the process was to winnow

15 down the universe of sources in Illino is based on the

16 criteria that Mike mentioned: the time frame, 1962

17 to 1977; the 26 source types; and then also the

18 emissions thresholds.

19 Once we got that group of sources narr owed

20 down, we had what we termed BART

- eligible sources,

21 and we looked at sulfur dioxide, oxides of nitrogen,

22 and primary PM since they are listed by USEPA as

23 being visibility impairing pollutants. And once we

24 determined those sources, then the process was to32

1 model each of those sources

-- a source here i s what

2 we commonly would refer to as a facility

--

3 extracting the emissions from our inventory system.

4 And at this point we did have a number of

5 interactions with industry folks to cor rect emissions

6 where they were in error or to update information on

7 the age of the stack and such, and we used for

8 emissions the maximum short

- term allowables.

9 The CALPUFF mode ling domain is very large,

10 going from the Atlantic Ocean to the front range of

11 the Rocky Mountains and down to the southern tip of

12 Florida and into Canada. What this means is that the

13 emissions that will come from the sources will remain

14 in the domain for an extended period of time, and

15 that's important for multiday pollutant events. We

16 see in the Midwest that regional haze sometim es is a

17 multiday event, and we can get transport from fairly

18 long range. So having a large modeling domain

19 ensures that we will capture the pollutants that form

20 regional haze.

21 The meteorology that drives this CALPUFF

22 model were developed by LADCO from a 36 kilometer

23 national scale MM5 model. MM5 being a prognostic

24 meteorological model. We used three years of33

1 meteorological data from 2002 to 2004. The reason we

2 took those years is because the rule came out in

3 2005. Therefore, they were the three most recent

4 years available. And each of the Class I areas

--

5 which I'll show you where they are in a second

-- had

6 multiple receptors placed in them in order t o

7 determine the culpability of Illinois sources.

8 And here are the Class I areas that were

9 included in our BART modeling. You see on the

10 northern extent of the domain the sourc es that Mike

11 has talked about. We also included Class I areas in

12 southern Missouri and then a series of them across

13 the southeastern United States up through the

14 mid

- Atlantic and into the northeastern United States.

15 Illinois followed the BART modeling protocol

16 that was developed by LADCO and the MRPO states. The

17 protocol addressed the model to be used, the

18 development of the inputs, and processing and

19 interpretation of the results. This modeling

20 protocol was developed in concert with USEPA. They

21 were always on our phone calls, and they did get the

22 ability to make a final approval of the protocol as

23 well as the federal land managers.

24 Now, based on the BART guidance from USEPA, a34

1 source is considered to be causing or contributing to

2 visibility impairment if the 98th percentile daily

3 change in visibility is greater than 0.5 deciviews as

4 compared to natural conditions. That's a fairly

5 complicated, longwinded type definition. In plain

6 English, what that meant in the modeling world is, if

7 we had 22 or more exceedances of the .5 threshold

8 occurring in three years at any Class I area or if

9 eight or more exceedances occurred in any one year,

10 the BART

- eligible units at that source are considered

11 to be subject to BART controls.

12 In Illinois we did not assume from the start

13 that CAIR was going to be better than BART.

14 Therefore, we explicitly modeled all of the EGU

15 sources

-- or all the EG U units that were

-- that fit

16 the criteria that were given to define BART

17 eligibility. And when we ran the CALPUFF model to

18 determine the number of exceedances of the .5

19 deciview stan dard, we found these results: All but

20 one EGU that we modeled was determined to be subject

21 to BART and, therefore, would be needing BART type

22 controls.

23 On the non

- EGU side, we only had two

24 facilities that had more than the 22 in three years35

1 or the eight in one year number of exceedances of the

2 deciview standard, and that was ExxonMobil and CITGO.

3 We did not have anybody submit modeling

4 explicitly to escape the subject

- to

- BART criteria,

5 but we did have modeling submitte d from Dominion

6 Kincaid that would support their proposed BART

7 control strategy. Their modeling was done with a

8 finer grid than our modeling was, but it was also a

9 smaller domain. Re member, our domain was basically

10 two thirds of the country. Their domain was much

11 smaller and only addressed the impacts at the Mingo

12 Wildlife Refuge in Missouri and Mammoth Cave National

1 3 Park in Kentucky.

14 And what their modeling showed was that their

15 proposed control strategy as compared to what's

16 called presumptive BART

-- and I will leave that for

17 a mome nt because I'm sure Rory will discuss that in

18 his section. But their control strategy is

19 comparable to what is considered to be presumptive

20 BART.

21 Now, we did an audit of that modeling using

22 the LADCO modeling protocol, using the large domain

23 that you saw earlier which contains more Class I

24 areas, and then also compared our results to36

1 presumptive BART and found that the results show that

2 the Kincaid Dominion proposal is comparable to

3 presumptive BART.

4 And with that, let Rory get into the approach

5 to BART control requirements.

6 MR. DAVIS: Okay. And as Scott showed you,

7 in Illinois we modeled all of our BART

- eligible

8 sources, and they're subject to BART if they're shown

9 to cause or contribute to visibility impairment. And

10 the only sources that we found in Illinois to be

11 subject to BART were our coal

- fired power plants and

12 the two petroleum refineries. In most cases with

13 these units, we had measures that we previously

14 agreed to, and we found those to result in greater

15 reductions than just applying BART; and in two cases,

16 CWLP and Dominion, IEPA pursued agreements with these

17 subject

- to

- BART EGUs.

18 Then Illinois

-- we compared presumptive BART

19 emission levels to the existing emi ssion reduction

20 requirements and commitments for the subject

- to

- BART

21 EGUs in Illinois, and then in all these cases we

22 found that the emission reductions from the

23 commitments we had pre viously made would be greater

24 than what we considered to be presumptive BART.37

1 And the requirements and commitments that

2 we're talking about are the MPS and CPS, the

3 multi

- pollutant standard and the combined pollutant

4 standard that are in the Illinois mercury rule, and

5 those

-- the MPS and CPS appl y to Ameren and Dynegy

6 and Midwest Generation. And then there was two MOUs

7 for Dominion Kincaid and CWLP.

8 The MPS and CPS affects, like I said, Ameren

9 and Dynegy and Midwest G eneration, and these three

10 companies account for 88 percent of all the Illinois

11 coal

- fired capacity. And these emission standards

12 were negotiated on a case

- by

- case basis during our

13 me rcury rule negotiations.

14 From the MPS and CPS, we anticipate 214,000

15 tons per year reduction in SO2 emissions and 90,000

16 tons of NOx reductions per year by year 2015. And I

17 be lieve it gets a little better as it goes past 2018

18 also.

19 Our MOU with Dominion Kincaid affected both

20 units. They're both subject to BART, and, like Scott

21 said, they

-- they co nducted the site

- specific BART

22 analysis for the Kincaid plant, including CALPUFF

23 modeling, to assess the visibility impacts of the

24 several different control alternatives they were38

1 considering. And the agreement we came to was

2 Dominion agreed to a low emission rate for NOx of

3 0.07 pounds per million BTU b y year 2017, and

4 presumptive BART for those Dominion units is .10.

5 So we're going to be below that. And also the

6 agreement requires an SO2 emission rate of .18

7 million BTU per

-- poun ds per million BTU by 2017.

8 Here the presumptive part is .15 pounds per million

9 BTU. And, as Scott said, the modeling shows that the

10 alternative plan results in equivalent visibility and

11 at a much lower cost.

12 For CWLP, CWLP had three BART

- eligible units:

13 Dallman 31, 32, and Lakeside 8. And our MOU

14 agreement with them has an agreement to shut down

15 Lakeside 8 altogether, and the presumptive BART for

16 these units

-- for the two remaining units is the

17 operation of an SCR. There's some requirements for

18 presumptive BART that are in pounds per million BTU.

19 The type of units that CWLP has

-- I believe they

20 don't have a pounds per million BTU limit. It's just

21 the operation of SCR. So that's

-- it's kind of

22 subjective there. And BART

-- or p resumptive BART

23 for SO2 is 95 percent control.

24 And CWLP agreed to meet an annual NOx39

1 emission ra te of .12 pounds per million BTU in 2015

2 and .11 pounds per million BTU in 2017. Also, for

3 SO2, they agreed to a rate of .25 pounds per million

4 BTU in 2015 and .23 pounds per million BTU in 2017.

5 And the calculated presumptive BART for SO2 for these

6 units is .3 pounds per million BTU, and the

7 calculated presumptive BART is just calculated from

8 95 percent of uncontrolled. And Illino is EPA

9 estimates that reductions from the CWLP MOU to be

10 around 5400 tons of NOx per year and 4800 tons of SO2

11 per year in the year 2017.

12 We have a nice graph showing

-- the ve ry far

13 left bars are 2002 base year, and then to the right

14 of that is the presumptive BART. The yellow there is

15 2018 CAIR estimates, and the very far right, the

16 maroon, is the Illinoi s requirements. And you can

17 see for NOx the Illinois requirements from our

--

18 from our agreements are better than presumptive BART

19 and CAIR estimates.

20 And then for SO2, you ha ve the same picture.

21 Again, the base year on the left, Illinois all the

22 way on the right with the presumptive BART and 2018

23 CAIR projections, and you can see the small hiccup on

24 Domini on from the MOU that I just talked about.40

1 And then for our non

- EGUs, like I said,

2 there's two petroleum refineries that we found to be

3 subject to BART

-- the CITGO refinery in Lemont and

4 Exxon refinery in Joliet

-- and both of these

5 refineries are subject to consent decrees. CITGO in

6 2004 and Exx onMobil in 2005. And both of these

7 consent degrees result in large reductions of NOx,

8 SO2, and PM in Illinois.

9 When we looked at the consent decrees, they

10 consider the same fa ctors or they're very similar to

11 what they consider for BART. And the emissions from

12 these consent decrees would have

-- are greater than

13 applying BART to both

-- to the subject

- to

- BART units

14 at the refineries in both cases. And, also, the

15 emission reductions from these consent decrees are

16 coming now in 2009 and 2010. It says "a few years

17 earlier." I believe the sulfur reductions are

18 already

-- already there at their FCCUs, for the most

19 part, and I think that they're almost done with all

20 of the controls they have to put on for the consent

21 decree. So we're get ting extra emission reductions

22 ahead of what we would have by applying BART.

23 And, in summary, we have several sources in

24 Illinois that have been determined to be BART41

1 eligible and causing or contributing to visibility

2 impairment in the Class I areas we discussed. And in

3 Illinois our plan has been

-- we've promulgated or

4 negotiated emissions control requirements for most of

5 the subject

- to

- BART sources, and these requirements

6 are providing reductions that are well beyond what

7 wo uld be anticipated from only applying BART to the

8 subject

- to

- BART units. And Illinois control

9 requirements will provide greater visibility

10 improvements than that would occur from just the

1 1 application of BART on the subject

- to

- BART units.

12 And that's what I've got.

13 HEARING OFFICER: Thank you, Rory.

14 Okay. I'm going to go ahead and open up for

15 questions or comments.

16 Any questions or comments?

17 Sir, if you'd come forward to the podium just

18 so that

--

19 MR. ELVERT: Sure. Just a clarification. My

20 name is Bob Elvert, E

- l

- v, as in "Victor,"

- e

- r

- t,

21 with ExxonMobil.

22 This first one is to Mike. One of your last

23 slides you had a regional emissions graph. I think

24 it was, like, the fifth to the last one. Just

-- is42

1 that

-- as far as the regional, is that region five?

2 How big is that region?

3 MR. KOERBER: Five

- state LADCO region:

4 Wisconsin, Michigan, Illinois, Indiana, Ohio.

5 MR. ELVERT: Is there a slide like that for

6 just the Illinois

--

7 MR. KOERBER: Yes.

8 MR. ELVERT:

-- BART facilities?

9 MR. KOERBER: I don't have one, but we could

10 work something like that up, I think. I'm sure you

11 gu ys have what the

-- you know what the facilities

12 are.

13 MR. LEOPOLD: Right.

14 MR. KOERBER: And the emissions.

15 MR. LEOPOLD: Right.

16 MR. D AVIS: Yeah.

17 MR. KOERBER: So I don't have that, but I

18 think the information is available.

19 MR. ELVERT: Okay. All right.

20 And then the second

-- second question is to

21 the IEPA. Just the last couple slides where, for the

22 coal

- fired plants, you had graphs showing the

23 estimated NOx emission reductions for both NOx and

24 SO2. Is there a similar s lide or information that43

1 shows that for the refineries in Illinois? Just to

2 show the reductions that you

-- from the cons ent

3 decrees.

4 MR. DAVIS: We do not have in our SIP

5 submittal, and the question for the EGUs

-- that's in

6 our BART and regional haze SIP in one of them. We

7 do n't have a graph like that, but we do have a table

8 of the emissions from the individual units from the

9 refineries.

10 MR. ELVERT: Okay. And is it possible to get

11 that

--

12 MR. DAVIS: Yeah. Both of those documents

13 are online.

14 MR. ELVERT: Okay.

15 MR. DAVIS: And we can

--

16 MR. KALEEL: It's in the documents, the B ART

17 documents.

18 MR. ELVERT: Okay. Thank you much.

19 HEARING OFFICER: Thank you.

20 Anyone else with questions or comments?

21 MR. DIERICX: My name is Rick Diericx,

22 D

- i

- e

- r

- i

- c

- x, with Dynegy Midwest Generation.

23 First question I had is for Mr. Koerber. I

24 think it was slide 12 of your presentation indicated44

1 that the CALPUFF model was used, and I think on slide

2 31 you mentioned the CAMx model. Were two different

3 models, in fact, used? And, if so, what were the

4 differences in the models? Why were they

-- what

5 were they used to illustrate?

6 MR. KOERBER: Right. Good question. The

7 CALPUFF model was used for the individual source

8 modeling as part of the BART analyses to determine

9 which BART

- eligible sources were subject to BART.

10 And then the CAMx regional air quality model

11 was use d as part of the long

- term strategy

12 assessment, specifically in defining and setting the

13 reasonable progress goals.

14 So, again, the two major provisions of the

15 Clean Air Act

-- one is BART, the other is long

- term

16 strategy. We use CALPUFF for the BART work, and we

17 use CAMx more

-- we use CAMx specifically for the

18 long

- term strategy development.

19 MR. DI ERICX: Okay. On slide 19 also of

20 Mr. Koerber's presentation, there was a graph showing

21 pollutant contribution bar charts, and I think they

22 indicated there were seven different pollutants that

23 affected visibility on there. Is that correct? Is

24 that

-- slide 19

-- is that the correct one?45

1 MR. KOE RBER: That is the correct one. The

2 dominant chemical species being sulfate, nitrate,

3 organic carbon, the yellow, red, and green portions.

4 MR. DIERICX: Okay. Are all seven pollutants

5 equally effective at impacting visibility?

6 MR. KOERBER: They have different levels of

7 effectiveness. In terms of their contribution to

8 light extinction, which is the metric that we'r e

9 depicting in this particular

-- on this particular

10 slide, sulfate, as you can see, is really the

11 dominant player in some of these Class I areas, but

12 nitrate and organic carbon also h ave an impact.

13 MR. DIERICX: And they're the dominant player

14 because of their quantity of emissions?

15 MR. KOERBER: Quantity as well as their

16 light

- impairing effectivene ss.

17 MR. DIERICX: Okay. Thank you. I think on

18 Scott's presentation, slide ten maybe which showed

19 IEPA CALPUFF results, indicated the model exceedances

20 for the various facilit ies. Which years of emissions

21 were used to determine those exceedances? Was it

22 historic emissions, or was it future emission rates?

23 MR. LEOPOLD: No, those are historic emission

24 rates. The emission rates were meant to depict 200546

1 emissions. This is consistent with the year that the

2 rule came o ut and also then consistent with the 2005

3 base year that was used in the LADCO modeling.

4 MR. DIERICX: Okay. And did they

-- the 2005

5 emissions

-- did those represent actual or allowable

6 emissions for those facilities?

7 MR. LEOPOLD: Allowable emissions.

8 MR. DIERICX: Okay. Okay. That's all the

9 questions I have. Thank you.

10 HEARING OFFICER: Thank you.

11 Anyone else with questions or comments?

12 MR. KALEEL: Dean, I would like to make a

13 comment on the record, if I could, and it might

14 prompt some more questions here, but there's

15 something I want to make sure was on the record.

16 HEARING OFFICER: Sure.

17 MR. KALEEL: Okay. I'm Rob Kaleel with the

18 Illinois EPA, air quali ty planning section.

19 And I just wanted to make sure that the folks

20 here were aware and that it's reflected in the record

21 that the regional haze rule requires that we share

22 our draft SIP documents with federal land managers at

23 least 60 days prior to today's public hearing, and

24 we, in fact, did that. We made our documents47

1 available a couple of months ago on our website. We

2 notified the participating federal land managers. I

3 believe they're primarily the U.S. Fish and Wildlife

4 Service, the U.S. Park Service, and the National

5 Forest Service. I think they were the three key

6 FLMs, federal land managers, that participated.

7 So we did

-- we did share these documents.

8 We've had one conference call with the FLMs a couple

9 of weeks ago to get preliminary comments, and then

10 last week we received formal written comments to our

11 SIP documents, the documents tha t are on our website

12 and that we're talking about today.

13 So I wanted people to be aware that that was

14 kind of a parallel process. We are required to

15 obviously seriously consid er those comments, since

16 these are federal agencies, and, you know, where

17 appropriate, make changes in our documents. So I

18 wanted to just make sure that everybody was aware

19 that that was going on.

20 HEARING OFFICER: Thank you.

21 MR. OSTREM: Real quick question. Are those

22 comments part of the record or are they

--

23 MR. KALEEL: They will be par t of our SIP

24 record, yes.48

1 HEARING OFFICER: For the record, you're

2 going to have to identify you rself.

3 MR. OSTREM: Sorry. Stan Ostrem. Last name

4 O

- s

- t

- r

- e

- m, with Dynegy Midwest Generation.

5 HEARING OFFICER: Any other questions or

6 comments?

7 Chris.

8 MR. ROMAINE: My name is Chris Romaine. I'm

9 manager of the construction unit in the air permit

10 section, and as long as Rob was giving some

11 information, I just wan t to remind people that we are

12 working in the permit section on going out and

13 issuing federally enforceable state permits for CWLP

14 and Kincaid. And obviously we have sent a copy of

15 th at to CWLP. I don't see anybody here from Kincaid,

16 do I?

17 MR. KALEEL: I don't think so.

18 MR. ROMAINE: Okay. So

--

19 HEARING OFFICER: Thank you.

20 Any other comments or questions? All right.

21 If not, I remind everyone that the record is

22 open until January 5.

23 If you have questions or comments that you

24 wo uld like to submit in writing, please submit them49

1 accordingly.

2 Thank you, and this hearing is adjourned.

3 (Hearing adjourned at 2:35 P.M.)

4

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2450

1 CERTIFICATE OF REPORTER

2 STATE OF ILLINOIS )
) ss. 3 COUNTY OF SANGAMON )

4 I, ROBIN A. ADAMS, a Registe red

5 Professional Reporter, Certified Shorthand Reporter,

6 and Notary Public within and for the State of

7 Illinois, do hereby certify that the foregoing

8 proceedings were taken by me to th e best of my

9 ability and thereafter reduced to typewriting under

10 my direction; that I am neither counsel for, related

11 to, nor employed by any of the parties to the action

12 in which thes e proceedings were taken; and further

13 that I am not a relative or employee of any attorney

14 or counsel employed by the parties thereto, nor

15 financially or otherwise interested in the outcome of

16 the action.

17

18

19 __________________________________

20 Notary Public in and for

21 the State of Illinois

22

23

24

### ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
BUREAU OF AIR

Responsiveness Summary for Public Questions and Comments on the State Implementation Plan Submittal to Address Regional Haze

May 31 , 2011

### 2



### I NTRODUCTION

Regional haze is visibility impairment caused by the cumulative air pollutant emissions from numerous sources over a wide geographic area. T o address the visibility protection requirements
of Section 169A of the Federal Clean Air Act for Federal Class I areas , e ac h state is required to submit an implementation plan for regional haze meeting the requirements of 40 CFR §51.308(d) and (e)

. The core requirements for the implementation plan for regional haze include reasonable progress goals, calculations of baseline a nd natural visibility conditions, long

- term strategy for regional haze, monitoring strategy, and emission limitations representing Best Available Retrofit Technology (“ BART ”) and schedules for compliance with BART for each BART

- eligible source that may rea sonabl y be anticipated to cause or contribute to any impairment of visibility in any mandatory Class I Federal area 40 CFR §51.308(e). Accordingly, a proposal has been prepared to satisfy Illinois’ obligation to develop a regional haze S tate I mplementatio n P lan with measures necessary to make reasonable progress towards remedying visibility impairment in Federal Class

I areas.

PUBLIC HEARING AND COMMENT PERIOD

The Illinois Environmental Protection Agency (Illinois EPA) he ld a public hearing on December 6, 2010, at 1:30 p.m.

, at the Illinois EPA’s Headquarters in Springfield, Illinois. The comment period closed on January 5, 2011.

COMMENTS AND RESPONSES BY THE ILLINOIS EPA

At Section 4.1.1, page 23, of the BART TSD, the Agency states in the first paragraph: “Appendix C contains the fully adopted Illinois Mercury Rule, with the relevant requirements for NOx and SO2 emission reductions highlighted. Illinois intends to submit these rules to USEPA to satisfy BART obligations for affected units at these three utilities. Ultimately, unit

- specific measures to comply with these requirements will be contained in federally enforceable permits.” (Emphasis added.)

Appendix C actually no longer contains the complete Illinois Mercury Rule, although the earlier draft of the BART TSD did contain the entirety of the rule. Currently, the Agency proposes to include in Appendix C only Section 225.233, which is the Multi

- Pollutant Standard (“ MPS”), and only some sections of the Combined Pollutant Standard (“CPS”).

The Commenter agrees that the submission should be limited to the sections proposed, but the language in the first sentence quoted above should be revised to reflect this

smaller su bmission.

The Illinois EPA agrees with this comment and has amended the Technical Support Document for Best Available Retrofit Technology Under the Regional Haze Rule, AQ PSTR 09

- 06
, April 29 , 2011
, accordingly

. The Illinois EPA will not be submitting the Illinois Mercury Rule in its entirety to the United States Environmental Protection Agency (―USEPA‖). Only those Sections that contain provisions of the rule that the Illinois EPA seeks approval from the USEPA will be

### 3



### included in the submission and those provisions are bolded in Appendix C of such Technical Support Document. It is important to note that the USEPA has already approved Subparts A, C, D, and E of 35 Ill. Adm. Code Part 225

. See , 40 CFR § 5 2.720(c )(178) (2010).

In the second sentence quoted above, the Agency says that it will submit “these rules” to USEPA to satisfy the BART requirement. A Commenter requests that the Agency clarify

its intention here. The Commenter understand s that the Agency intends that only the highlighted portions of the rules included in Appendix C should become part of the BART or Regional Haze SIP and that the non

- highlighted portions of the rules are being submitted merely for the purpose of providing c ontext for USEPA and other readers. The

Commenter requests that the Agency make clear in the BART TSD that although the entirety of Appendix C will be submitted to USEPA, only the highlighted portions of the rules included in Appendix C will become part o f the SIP.

The Illinois EPA agrees with this comment and will not be submitting the Illinois Mercury Rule in its entirety to the U nited States Environmental Protection Agency (―U SEPA ‖)

. As stated previously, o nly those Sections that contain provisions of the rule that the Illinois EPA seeks approval from the USEPA will be included in the
submission and those provisions are bolded in Appendix C of the Technical Support Document for Best Available Retrofit Technology Under t he Regional Haze Rule, AQPSTR 09

- 06, April 29 2011

.

A Commenter requests clarification regarding what the Agency intends with respect to
“unit

- specific measures” to be included in federally enforceable permits. The CPS requires a company to install certain pollution control equipment on some units (not all) by specified dat es, which would be the subject o f a state construction permit for each. Other than that, the CPS requires a company to comply with system

- wide average

emission rates f

or NOx and SO 2



### . A Commenter is not clear as to how these CPS requirements translate into “unit

- specific measures” and suggest to the Agency that perhaps a more general statement to the effect that the CPS requirements will be reflected in federally enforc eable permits would be more appropriate.

The Illinois EPA agrees with this comment and has clarified the wording in the Technical Support Document for Best Available Retrofit Technology Under the Regional Haze Rule, AQPSTR 09

- 06, April 29, 2011.

A Commenter pointed out factual errors in the “draft” version of the Technical Support Document for Best Available Retrofit Technology Under the Regional Haz e Rule, AQPSTR 09

- 06, September 30, 2010

, and requested correction of those errors.

The Illinois EPA has corrected these factual errors in the final version of the document

.

### 4



### Concerning Appendix C :

Section 225.292(a): A Commenter notes that the Agency does not propose to include the provision of the MPS that corresponds to Section 225.292(a) of the CPS as part of the

SIP. See Section 225.233(a)(1) and (2). Likewise, the Commenter suggests that inclusion of any subsection of Secti on 225.292 in the BART/Regional Haze SIP is unnecessary and inappropriate and requests that the Agency delete this section from

inclusion in its submittal.

A fter discussions with the USEPA, the Illinois EPA is including both Sections 225.292(a) and 225. 233(a). These subsections (a) in both Sections describe the election by owners to comply with 35 Ill. Adm. Code Part 225 under the alternative

method of compliance
, which is either the Combined Pollutant Standard or Multi

Pollutant Standards.

Section 225.296(e): A Commenter believes that there is no rational basis for including this subsection in the SIP. The subsection includes a reference to Section 225.296(c), which, appropriately, is not be included in the SIP, as well as a reference to a ir pollution control equipment for purposes of reducing mercury and PM emissions, neither of which are factors in the BART/Regional Haze SIP.

The Illinois EPA is submitting subsection (e) of Section 225.296, because visibility

impairing pollutants include particulate matter , along with sulfur dioxide and nitrogen oxides

. See , Appendix Y to 40 CFR Part 51

— G uidelines for BART Determinations Under the Regional Haze Rule. However, the Illinois EPA is not bolding the term ―mercury‖ in subsection (e), and there fore, is not requesting that provisions relating to mercury be included in this submission. The United States Environmental Protection Agency has indicated that it has no intention of imposing any mercury provisions of any sort upon affected sources under this proposal.

Section 225.299: A Commenter suggests that inclusion of Section 225.299 would be appropriate in this SIP. This is the section that provides that the CPS represents BART

for SO 2 

### , among other things.

―Best available retrofit technology‖ is defined as ―an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant which is emitted by an existing stationary facility. The emission limitation must be established, on a case

- by

- case basis, taking into consideration the technology available, the costs of compliance, the energy and nonair quality environmental impacts of compliance, any pollution control equipment in use or in existence at the source, the remaining useful life of the source, and the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.‖ 40 CFR § 51.301. Section 225.299 includes a statement, not an emission lim itation. It is the approval of the Regional Haze S tate I mplementation P lan submission by USEPA that would reflect

### 5



### that Illinois’ approach
, including the C ombined P ollutant S tandard and M ulti

P ollutant S tandards, represents BART.

A nother Commenter pointe d out factual errors in the “draft” version of the Technical Support Document for Best Available Retrofit Technology Under the Regional Haz e Rule, AQPSTR 09

- 06, September 30

, 2010

, and requested correction of those errors.

The Illinois EPA has corrected these factual errors in the final document

.

A Commenter stated that t he inclusion of 35 IAC 225.233(e)(1) and (e)(2) as part of Illinois’ federally

- enforceable BART rule would subject non

- BART units to federally enforceable BART requirements even though t hey are not BART eligible sources. The Commenter also suggested that the Illinois EPA rely on a federally

- enforceable consent decree to satisfy BART obligations

for certain units due to the fact that the federal consent decree imposes more stringent or

eq uivalent NOx and SO 2 

### limits on the such units than 35 IAC 225.233(e)(1) and (e)(2) and sooner than required by 35 IAC 225.233(e)(1) and (e)(2), and since there are no BART eligible

units at the sources , and since the Commenter has the only EGU’s impacted by 35 IAC 225.233(e)(1) and (e)(2), the Commenter recommends that the Illinois EPA exclude 35 IAC 225.233(e)(1) and (e)(2) from this rulemaking.

Under the BART requirements for Regional Haze visibility impairment, the State must submit an implementation plan containing emission limitations representing BART and schedules for compliance with BART for each BART

- eligible source that may reasonably be anticipated to cause or contribute to any impairment of visibility in any mandatory Class I Federal area, unless the State demonstrates that an emissions trading program or other alternative will achieve greater reasonable progress toward natural visibility

co nditions. 40 CFR § 51.308(e). S uch an emissions trading program or other alte rnative measure must achieve greater reasonable progress than would be achieved through the installation and operation of BART. Id

. The Illinois EPA’s alternative approach includes
, but is not limited to, the Multi

- Pollutant Standards (―MPS‖) and Combine d Pollutant
Standard (―CPS‖) under the Illinois Mercury Rule, 35 Ill. Adm. Code Part 225, and provides greater emissions reductions
, and thus
, greater reasonable progress than would have resulted from the installation and operation of BART at the covered s ources. Accordingly, the Illinois approach does not rely on consent decrees for utilities

.

Sources electing to comply with the emis sions standards under the MPS and CPS are required to submit an application for a Clean Air Act Permit Program (―CAAPP‖) permit modification to the Illinois EPA. 35 Ill. Adm. Code 225.233(a)(3) and 225.292(c) . Each CAAPP permit issued by the Illinois EPA for a source must contain federa lly enforceable conditions addressing all applicable requirements. 35 Ill. Adm. Code 225.220(c)(1).

### 6



### Section 4.2.2

– A Commenter pointed out that ExxonMobil's Consent Decree has been revised,

and the SCR is required by 12/31/2010, not 12/31/2012. Thus, NOx emission reductions in Table 4.15 will be achieved beginning in calendar year 2011. In addition, SO2 emission decreases in Table 4.16 have already been achieved, beginning with calendar year 2009.

The Illinois EPA agrees with this comment and h as amended the document accordingly

.

Section 4.2.1, a Commenter noted that "grams per dry standard cubic foot hydrogen sulfide" should read "grains per dry standard cubic foot hydrogen sulfide".

The Illinois EPA agrees with this comment and has amended the document accordingly

.

A Commenter asked the Illinois EPA to d efine "presumptive BART" for refinery sources, including process heaters, non

- EGU boilers, FCCs, SRUs, flares. In addition, the Commenter requested that the Illinois EPA c larify the diff erence between "Presumptive BART" and

"Consent Decree 2013" (see tables 4.15 and 4.16 in "Draft TSD for BART under the Regional

Haze Rule ”).

The Illinois EPA agree s that the terminology for "presumptive BART" for refineries used
in the draft document is confusing. The BART rule does not contain "presumptive BART" limits for refineries in the same way as it does for utilities. The Illinois EPA is t rying to compare th e amount of reduction that Illinois would expect from implementation of BART

controls (scrubbers, SCRs) on subject units versus the reductions expected from the

consent decree. The Illinois EPA’s intent is to show that the consent decree will provide greater reductions than BART. In the final document, the Illinois EPA has revise d the

ter minology to reflect "expected BART reducti on.‖

A Commenter inquired as to whether an analysis based on actual emissions will suffice or will

there need to be a PTE analysis. The Commenter also inquired about whether 2002 PTE and "Presumptive BART & "Consent Decree 2013" calculated based on a reduction from 2002 actual

emissions will meet US EPA's standards

.

The U nited S tates E nvironmental P rotection Agency (―USEPA‖) did not comment on the
Illinois EPA’s draft documents ; however, the USEPA has accept ed the refinery consent decrees as meeting BART in other states. Therefore, the Illinois EPA believe s that the
Illinois approach is approvable.

### 7



### Will there be any revisions to 35 IAC Subpart C "Emissions Standards and Limitations for Stationary Sources" in support of the Consent Decree approach? If yes, the Commenter requests the opportunity to review the proposed language in advance of the IPCB rulemaking.

Assuming that the reference is to Part 217 , Nitrogen Oxides Emissions, the Illinois EPA

does not intend to revise it to reflect the consent decree limits. The Illinois EPA’s a pproach is to rely on federally

- enforceable permits to implement BART for the refineries.

The following comments were submitted by the United States Department of the Interior, Fish

and Wildlife Service:

Baseline, Natural Condition, and Uniform Rate

– In the executive summary, three specific Class I areas are identified for which emissions from IL sources cause or contribute to visibility impairment. These Class I areas include Mammoth Cave NP, Mingo NWR, and Isle Royale NP. More information should be presented explaining how only these 3 Class I areas, and no others, were selected. For the selected Class I areas, the SIP should include discussion about the baseline and natural conditions estimates, and uniform rate of progress. This information is important because IL uses these data in making its control determinations. Although these values are established by neighboring States, the resulting baseline and natural conditions estimates affect IL and its subsequent work. If it is determined that IL significantly contributes

to a dditional Class I areas, summary information should be included for them as well.

The Executive S ummary of the draft Technical Support Document, Regional Haze State Implementation Plan for Illinois, AQPSTR 1 0

- 08
, October 7, 201 0
, indicates that Illinois causes or contributes to visibility impairment ―in several Class I areas

... , including
Mammoth Cave National Park

... , the Mingo Wilderness Area..., and Isle Royale National

Park... ‖ The Illinois EPA did not intend to state that only the three Cl ass I areas
refer enced in the Executive Summary were addressed. Accordingly, this sentence has been

amende d so as to include, but not limit, the reference to just those three Class I areas. The body of such Technical Support Document , particularly in Section 9.0, provide s additional detail on Illinois’ visibility impact on Class I areas across the central and eastern United
States.

Emission Inventories and Modeling

– IEPA participated in joint emission inventory and air quality modeling efforts with the Mid

- West Regional Planning Organization (RPO) . In order for

the State to make use of the modeling results, it should present a summary of efforts, participation, an d technical assumptions associated with RPO modeling products . Establishing validity of the modeling system is required for all non

- guideline model applications. The discussion should include development and application of meteorology, modeling systems, performance evaluation, and all associated emission inventories . Uncertainties regarding each of the previous components, as well as methods (such as reasonable response factors) to reduce predictive e rror, should be discussed. These effort s are ultimate ly the basis for the State’s conclusion that visibility goals are being met and that IL is fulfilling its share of reducing visibility impairment . In addition, IL is unique ly located near multiple RPOs. The State should

### 8



### consider a review of the competing efforts made by CENRAP, VISTAS, and MANE

- VU

, summarize those RPOs’ emission inventory and modeling systems, and make comparisons on

how contributions from IL were characterized

.

Components of the modeling platform, their implem entation, and their perform ance are documented in the Regional Air Quality Analysis for Ozone, PM 2.5 

### , and Regional Haze: Final Technical Support Document, April 25, 2008
, included in the submittal as Appendix

B to the Regional Haze State Implementation Plan for Illinois, AQPSTR 10

- 08
, May 10,

2011. The document has also been amended to describe the efforts of the Central Regional Air Planning Association (― CENRAP ‖)
, Visibility Improvement State and Tribal
Association of the Southeast (― VISTAS ‖) , and Mid

- Atlantic/Northeast Visibi lity Union (― MANE

- VU ‖)

.

Reasonable Progress Goals and Long Term Strategy

– Although the Class I States set the reasonable progress goals for each of their Class I areas, IL should summarize these goals and

discuss its air pollution sources’ apportionment to baseline in meeting these goals for each of the

affected Class I areas. From our experience, all RPO’s performed some form of State level apportionment calculations for its Class I areas. IL should look beyond only Mid

- West RPO in making these findings.

Additional documentation pertaining to Reasonable Progress, such as the M idwest

R egional P lanning O rganization five factor analysis, and excerpts from the Mid

Atlantic/Northeast Visibility Union (― MANE

- VU ‖) and the Visibility Improvemen t State
and Tribal Association of the Southeast (― VISTAS ‖) documents showing that the Uniform Rate is achieved and exceeded at their Class I sites by 2018, has be en added to Section 7 .0
of the Regional Haze State Implementation Plan for Illinois, AQPSTR 10

- 08
, May 10, 2011

. Section 8.0, Long Term Strategy, has been enhanced with additional detail about future

controls and N ew S ource R eview /P revention of Significant Deterioration considerations.

Consider summarizing how the IL specific emission control efforts affect the Class I areas’ ability to meet the R easonable P rogress G oal s. One way is to discuss sources and associated controls specific to an “area of influence” for each Class I area. With this method, a geographic area is identified as a likely contributor to a Class I area’s primary impairment influence. By discussing how State emission control regulations apply in these areas and ultimately assist in improving visibility, a State can better justify that sufficient efforts were made to pursue
“reasonable” controls.

The Illinois EPA has participated in numerous consultations with other states and Regional Planning Organizations

. These consultations are complete , and no other state has requested that the Illinois EPA consider further controls f or Regional Haze. The Illinois

EPA believe s that the S tate’s aggressive control programs, especially in the utility sector where controls go beyond proposed national rules, satisfy Reasonable Progress Goals.

### 9



### Finally, IL should better identify how its St ate emission control strategies relate to the four

factors outlined at 40 CFR 51.308(d)(1)(i)(A) . Simply identifying RPO model ed projections of visibility improvement at assorted Class I areas as meeting the uniform rate of progress is not enough in showing that IL indeed met its share of emission controls

. A four factor analysis is

intended to show that emission sources, or categories of sources, have been evaluated and

determined to be “reasonable”. The fact that a neighboring Class I State did no t specifically ask for additional controls does not relieve the need for a comprehensive evaluation of Illinois’ air quality emission controls

.

Excerpts from the factor analysis discussion, which is contained in the Regional Air Quality Analysis for Ozone, PM 2.5 

### , and Regional Haze: Final Technical Support Document, April 25, 2008 ( see , Appendix B to the Regional Haze State Implementation Plan for Illinois, AQPSTR 10

- 08
, October 7, 2010) have be en added to Section 7 .0

. The factor analysis demonstrates that electric generating unit controls are by far the most effective at providing signif

icant improvement in visibility at a reasonable cost.

BART

– The suggestion to add supporting discussion and information also apply to the BART

process a nd BART determinations. We recommend that a full summary, with added detail, be included in describing the “better than BART” option IL has chosen . With the limited number of sources subject to BART, it also appears reasonable to summarize each BART sour ce and

describe the benefit from the BART alternative.

For most of the subject

- to

- BART sources in Illinois, the Illinois EPA has relied on existing emission reduction requirements and commitments, comparing the reductions from these control programs to th e reductions that would have been achieved by applying BART controls. The existing control programs include the Multi

- Pollutant Standards (―MPS‖) and Combined Pollutant Standard (―CPS‖) codified in the Illinois Mercury Rule, 35 Ill. Adm. Code Part 225, th at apply to Ameren, Dynegy, and Midwest Generation, and federal consent decrees, which establish enforceable emission limits for petroleum refineries that have resulted, or will result, in significant reductions in SO 2 

### and NO

x 

### emissions. The
Illinois EPA’s analysis of emission reductions that will result from implementation of the MPS and CPS for electric utilities and from implementation of the consent decrees for the refineries demonstrates conclusively that Illinois’ approach will yield much larger
reductions of NO

x 

### and SO 2 

### than will implementation of BART controls on just subject

- to

BART emission units. These control programs are described in the final Technical Support Document for Best Available Retrofit Technology Under the Regional Haze Rule,

A QPSTR 09

- 06, April 29, 2011. The relevant portions of the fully adopted Illinois Mercury Rule, with the requirements for NOx and SO 2 

### emission reductions highlighted, are included as Appendix C of this document. Copies of the federally enforceable consent decrees for the two petroleum refineries that are subject to BART are included as Appendices E and F.

### 10



### Because the better

- than

- BART alternative compares emission controls against presumptive control levels established for EGUs, additional summary should be included for what would constitute BART levels for refineries. We suggest that the discussion include a five factor analysis , per 40 CFR 51.308(e)(1)(ii)(A), for each of the refineries in support of the alternative

.

For the two petroleum refineries in Illinois that are subject to BART, the Illinois EPA has relied on federal consent decrees to meet the BART requirement. These consent decrees establish enforceable emission limits for petroleum refineries based on the a pplication of selective catalytic reduction (―SCR‖) technology for control of NOx emissions, and flue gas desulfurization (―FGD‖) technology for control of SO2 emissions. The consent decrees also require reductions from emission units that are not subject to BART. The Illinois EPA’s analysis of emission reductions that will result from implementation of the consent decrees for the refineries demonstrates conclusively that the consent decrees will yield greater
reductions of NO

x 

### and SO 2 

### than will implement ation of BART controls on just subject

- to

BART emission units.

FIRE

– IEPA should summarize its smoke management plan. The summary should include

additional information to address the following questions :
I s the SMP volunta ry or mandatory?

Does the SMP consider Class I areas as sensiti ve receptors for burn decisions? Does the State implement best m anagement practice requirements for burning? and,

Is there an effort to track fire emissions from all styles of burning?

The Smo ke Management Plan is voluntary and targets ecological burns. Such Plan requires Best Management Practices for burns and the use of the Air Quality Index to inform the decision process. Section 8.3 of the Regional Haze State Implementation Plan for Illinois, AQPSTR 1 0

- 08
, May 10, 2011 , has been amended to provide more information
about the Illinois EPA ’s Smoke Management Plan.

Prevention of Significant Deterioration

– IEPA should also consider summarizing the implementation and review of PSD permits and its value toward prog ress with the Regional Haze Rule. Although new sources are generally considered cleaner sources, an improperly located new source or major modification can have a profound effect on a State’s ability to meet its progress goals.

The Illinois EPA has amended the Regional Haze State Implementation Plan for Illinois, AQPSTR 10

- 08
, May 10, 2011
, to address this issue. See
, Section 8.2. The visibility impacts of such sources will remain under the purview of existing requirements unde r Prevention of Significant Deterioration (―PSD‖). See , 40 C.F.R. § 52.21. The Illinois EPA administers the PSD program in Illinois under authority provided by Section 9.1 of the
Environmental Protection Act , 415 ILCS 5/9.1 (2010)
, and a delegation agreement with the USEPA authorizing Illinois to enforce the Federal PSD regulations.

### 11



### There seems to be a misinterpretation of Section III of the EPA BART Guidelines that provides for exempting a BART

- eligible source from being subject

- to

- BART if the source’s impact on visibility impairment from NO

x 

### , SO 2 

### and particulate matter (combined) at any Class I area is less

than 0.5 deciviews. 1 

### Section 3.0 of the Technical Support Document states, “. . . the MRPO determined that the visibility impact of particulate matter emissions from just the BART

- eligible sources in the MRPO states will be much less than 0.5 deciviews in any Class I area. Illinois EPA has therefore excluded emissions of particulate matter from the BART review process in

Il linois.” Visibility impacts of particulate matter must be included with NO

x 

### and SO 2 

### in modeling for determining if a source is subject

- to

- BART by contributing to visibility impacts at any Class I area by 0.5 deciviews or greater. However, it is agreed th at once a source is found to be subject

- to

- BART, controls on particulate matter emissions from an emission unit may be found to be so insignificant that the cost of control is excessive and addition of particulate matter emission controls is not required u nder BART. Section 3.0 of the Technical Support Document should clarify this concept and IEPA should confirm that no BART

- eligible source was found to be not subject

- to

- BART, because particulate matter was excluded from the modeling analysis in

determinin g the source’s contribution to visibility impairment at any Class I area.

The Illinois EPA agrees with this comment and has clarified the wording of Section 3.0 of

the final Technical Support Document for Best Available Retrofit Technology Under the Regional Haze Rule, AQPSTR 09

- 06, April 29, 2011. To ensure that no BART

- eligible source was found to be not subject

- to

- BART, because particulate matter was excluded
from the mode ling analysis, Illinois EPA performed additional CALPUFF modeling to determine the visibility impact of particulate matter emissions from the largest of the not

subject

- to

- BART sources, the Dynegy

– Wood River power plant. As described in Section 3.0, the modeling results confirmed that particulate matter emissions do not significantly affect the determination of sources that are subject

- to

- BART and that that no BART

eligible source was found to be not subject

- to

- BART, because particulate matter was

exclud ed from the modeling analysis.

The Technical Support Document seems clear that IEPA is requiring Electric Generation Units (EGUs) to perform a BART determination, rather than participate in the Clean Air Interstate Rule (CAIR). This is certainly an accep table position for the State to take, but possibly a sentence should be added to the Technical Support Document that confirms this to be the policy

of IEPA.

The Illinois EPA does not completely agree with this characterization of its approach to

address ing the BART requirement for EGUs. Illinois’ approach relies on the use of existing emission reduction requirements and commitments for EGUs that it has

demonstrated are a better

- than

- BART alternative. The Illinois EPA agrees that its

1 See 40 CFR Part 51, Appendix Y. The U.S. Environmental Protection Agency finalized its BART Guidelines on June 15, 2005, and published the preamble and final rule text in the Federal Register on July 6, 2005. The rulemaking action added Appendix Y to Part 51, titled “Guidelines for BART Determinations Under t he Regional
Haze Rule.” See Section III.A.1.

### 12



### approach does not r ely on the Clean Air Interstate Rule ( ― CAIR ‖ ) to meet its obligations

u nder BART.

A state choosing to use an alternative method to meet BART must demonstrate that this alternative measure will achieve greater reasonable progress than would be achieved through the installation and operation of BART. 2 

### Pertaining to Dominion Kincaid, Table 4.10 of the Technical Support Document shows only that the proposed alternative matches the aggregate total across analyzed Class I areas of 21 days with impacts grea ter than 0.5 deciviews as shown for presumptive BART, but does not exceed it. Thus, it would seem to demonstrate that the alternative method is equivalent to BART, but does not show greater reasonable progress than BART. Further, this demonstration must show that visibility does not decline in any Class I

area. 3 

### Table 4.10 shows that at under the alternative method at Mingo there is an increase in the number of days with impacts greater than 0.5 deciviews from three to five and also at Hercules

Glades th ere is an increase from one day to two days. Measures should be taken so that these increases under the alternative method become decreases. It is likely that this could be achieved by Dominion Kincaid if the emission control technology for SO 2 

### , likely a wet scrubber, were required under emission limitations to reach an efficiency of 0.15 lb/MMBtu, rather than the 0.18 lb/MMBtu as stated in section 4.1.2.2. As discussed in the following paragraph the emission

limitation could even be around 0.07 lb/MMBtu , which is the true efficiency of the technology. The United States Environmental Protection Agency commented similarly to the Illinois EPA.

Based on this comment from the U.S. Fish and Wildlife Service and a similar comment
from the USEPA, the Illin ois EPA and Dominion revised their original agreement to achieve greater reductions of SO 2 

### at the Kincaid power plant. The original agreement between Dominion and the Illinois EPA required that SO 2 

### emissions be reduced at Kincaid from the current rate of 0.46 lbs/mmBTU to a rate of 0.20 lbs/mmBTU by January 1, 2014, and to 0.18 lbs/mmBTU by January 1, 2017. In subsequent discussions, Dominion agreed
to further reduce SO 2 

### emissions at the Kincaid pl ant to a rate of 0.15 lbs/mmBTU, which meets the presumptive BART emissions limit. Dominion has also agreed to meet the NOx emission rate of 0.07 lbs/mmBTU, in accordance with the original agreement with Illinois EPA. This emission rate is considerably m ore stringent than the presumptive BART
emission limit for NO

x 

### of 0.10 lbs/mmBTU. The Illinois EPA has performed additional CALPUFF modeling to assess the visibility improvements of the revised agreement. The Illinois EPA’s modeling confirms that Dominio n’s final control plan for the Kincaid facility will provide greater visibility improvements than the presumptive BART emission limits. The revised agreement and Illinois EPA’s modeling are described in Section 4.1.2.2 of the
final Technical Support Docum ent for Best Available Retrofit Technology Under the Regional Haze Rule, AQPSTR 09

- 06, April 29, 2011.

2 See 40 CFR 51.308(e)(2).

3 See 40 CFR 51.308(e)(3)(i).

### 13



### Case

- by

- case BART determinations for EGUs should involve permitted emission limitations based on the capability of the emission control technology b eing implemented, rather than simply reflecting presumptive BART. In the various agreements with the sources, IEPA seemed to negotiate emission limitations that met presumptive BART control levels, rather than the capability of the control technology (e.g ., 0.06

- 0.07 lb/MMBtu for SCR; 0.05 lb/MMBtu for wet scrubbers). Although the premise of the alternative method of compliance focuses on meeting presumptive BART, the intent of the regional haze program is to maximize visibility improvement. This could best be achieved by setting emission limitations in permits to the level achievable by the control technology.

The Illinois EPA does not agree that negotiated emission limits for EGUs were designed to meet presumptive BART control levels. For most of t he subject

- to

- BART EGUs in Illinois, the Illinois EPA has relied on existing emission reduction requirements and commitments that reflect the capability of the control equipment that has been or will be installed on

coal

- fired EGUs in Illinois. Tables 4.2 through 4.12 in Section 4.0 of final Technical Support Document for Best Available Retrofit Technology Under the Regional Haze Rule, AQPSTR 09

- 06, April 29, 2011 demonstrate conclusively that the emission reductions that will be achieved by Illinois’ agr eements greatly exceed the reductions that would have been achieved by applying presumptive BART control levels. Reductions of SO 2 

### emissions from presumptive BART controls on subject

- to

- BART EGUs are estimated to total about 134,000 tons per year. Under Illinois’ agreements with the EGUs in the state, reductions of
SO 2 

### emissions will exceed 260,000 tons per year when fully implemented. Similarly, presumptive BART controls would have yielded a reduction of NOx emissions of 77,000 tons per year from Illino is EGUs. Under Illinois’ agreements, reductions of NOx emissions
will exceed 11 0 ,000 tons per year when fully implemented.

Proof that an alternative method results in greater reasonable progress for visibility improvement should involve presentation of modeling results as was done for Dominion Kincaid. Modeling results were not shown in the Technical Support Document intendin g to demonstrate that the alternative method(s) used for the other sources resulted in greater reasonable progress than BART. Aggregate lower emissions were shown for all EGUs, which would presumably result in greater visibility improvement at all Class I areas, but the conclusion is not definitive without modeling.

The Illinois EPA does not agree that is necessary to perform modeling to conclude that visibility improvements will result from the agreements made to reduce SO 2 

### and NOx emissions from the subject

- to

- BART sources in Illinois. Modeling performed by the Midwest Regional Planning Organization, as described in Regional Air Quality Analysis for Ozone, PM 2.5 

### , and Regional Haze: Final Technical Support Document, April 2 5, 2008 ( included in the submittal as Appendix B to the final Technical Support Document for Best Available Retrofit Technology Under the Regional Haze Rule, AQPSTR 09

- 06, April 29, 2011)
, demonstrates that reasonable progress goals are achieved assuming reductions from

EGUs consistent with CAIR and with the consent decrees on refineries. Illinois’ agreements with EGUs provide emission reductions that greatly exceed the reductions that

woul d be achieved by CAIR and also greatly exceed the reductions that would be achieved

### 14



### by meeting presumptive BART control levels on subject

- to

- BART units. Further, the
emission reductions from EGUs will result from controls from the entire fleet of units

ac ross the state. Given the distance from Illinois’ sources to Class I areas in other states, and the magnitude of emission reductions, it is clear that Illinois has met its obligation to ensure reasonable progress for visibility improvement.

Some additio nal explanation seems to be necessary in the CITGO refinery analysis which attempts to show that NO

x 

### reductions under the Consent Decree exceed NO

x 

### reductions that would be required under BART. First, the presumptive levels of emission control apply only to electric generation units and not to refineries. Therefore, the “Presumptive BART” column in

Table 4.13 should reflect NO

x 

### emission reductions attributable to actual BART controls, rather than presumptive levels of control. Second, Table 3.4 lists all the units that are subject to BART, but Table 4.13 in the BART column shows no BART controls for many of the refinery heaters that are subject to BART. Many NO

x 

### control technologies exist for the various types of refinery heaters and fuel types. The ext ensive number of combinations of technologies, types of heaters and fuel types are too extensive to discuss here. For discussion purposes a reasonable alternative to choose might be Ultra Low NO

x 

### Burners (ULNB) which is generally a feasible and cost

effec tive NO

x 

### control technology for refinery heaters that can achieve a 75% reduction in NO

x 

### . A BART determination should be performed for each of the heater units that are subject to

BART and units for which ULNB or other controls are feasible should show th e NO

x 

### control achievable for those units. Third, Section 4.2.1 explains that selective catalytic reduction (SCR) on the Fluid Catalytic Cracking Unit (FCCU) can achieve a 95% NO

x 

### reduction, but Table 4.13 reflects only 85% control. If 95% NO

x 

### control for the FCCU (1,011 TPY) is assumed, along
with 75% NO

x 

### control for the heaters that are subject to BART, the total NO

x 

### control achieved by BART levels of control is 1,456 tons per year. The column showing tons per year reductions

under the Consent Decrees i ndicates that only 1,268.5 tons per year will be achieved. This is not adequate for the CITGO refinery to meet the requirements of BART. Please perform additional analysis and/or add more NO

x 

### controls on refinery heaters to allow the facility to meet BAR T by assuring that Consent Decree and BART requirements exceed what would be required by BART.

The Illinois EPA agrees that the terminology for "presumptive BART" for refineries used
in the draft document is confusing. The BART rule does not contain "presumptive BART" limits for refineries in the same way as it does for utilities. The Illinois EPA is trying to compare the amount of reduction that Illinois would expect from implementation of BART controls (scrubbers, SCRs) on subject units versus the reductions expected from the

consent decree. The Illinois EPA’s intent is to show that the consent decree will provide greater reductions than BART. In the final document, the Illinois EPA has revised the terminology to reflect "expected BART reduction.‖

As stated in the final Technical Support Document for Best Available Retrofit Technology Under the Regional Haze Rule, AQPSTR 09

- 06, April 29, 2011 (―TSD‖) , the Illinois EPA has determined that the control measures required by consent decrees for petrole um refineries are sufficient to satisfy the BART requirement. The consent decrees require NOx reductions from certain process heaters in addition to the reductions required from

the fluidized catalytic cracking units (― FCCUs ‖)

. The consent decrees in Uni ted States of

### 15



### America, et al. v. CITGO Petroleum Corporation, et al ., Civil Action No. H

- 04

- 3883 (S.D. Texas 2005) , and United States of America, et al. v. Exxon Mobil Corporation, et al ., No. 05

- CV

- 05809 (N.D. Ill. 2005) , allow the refineries the flexibil ity to determine which process heaters can most effectively be controlled, considering many of the same factors required
for a BART determination. The tables in the final TSD identify the emission units that are being controlled under the consent decrees and have been modified to reflect that emission reductions from these same units are expected under BART. The Illinois EPA agrees with the comment that the NOx control efficiencies for SCRs applied to the FCCU were inconsistently applied in the draft docu ment. It should be pointed out that the consent decrees do not require a specific control efficiency, but it is reasonable to expect that the
SCR control efficiencies will achieve NOx removal efficiencies of 90% or greater. The
tables and text in the fin al report were amended to reflect 90% control of NOx from the installation of SCR at both refinery FCCU s

.

The discussion for the ExxonMobil refinery is similar to the discussion above for the CITGO refinery. The subject

- to

- BART refinery heaters (partic ularly points 18, 19, 21 and 25) show that no controls are required in the column for BART NO

x 

### reductions. Some level of control should be added to this column. For example, adding ULNB controls (at 75% reduction) would seem to

be a feasible control for these units. The sum of these numbers under the BART column would make it larger than the to ns per year reductions shown in the Consent Decree column. Again, please perform additional analysis or add more NO

x 

### controls to allow the facility to meet BART. Regarding the BART analysis for SO 2 

### , the Refinery Waste Gas Blowdown System and 2 Flares

is shown to be subject

- to

- BART. It would seem that the 1,156 tons per year of SO 2 

### from this system, at some percentage control level, should be included in the BART column. If this occurred the required tons per year reductions in the BART column would exce ed the tons per year of SO 2 

### reduced in the Consent Decree column and additional BART controls would need to be found. This could possibly be a flue gas recovery unit on the flares.

The Illinois EPA has determined that the control measures required by con sent decrees for petroleum refineries are sufficient to satisfy the BART requirement. The consent decrees require NOx reductions from certain process heaters in addition to the reductions required
from the FCCUs. The consent decrees in United States of A merica, et al. v. CITGO Petroleum Corporation, et al ., Civil Action No. H

- 04

- 3883 (S.D. Texas 2005) , and United States of America, et al. v. Exxon Mobil Corporation, et al ., No. 05

- CV

- 05809 (N.D. Ill. 2005)
, allow the refineries the flexibility to determin e which process heaters can most effectively be controlled, considering many of the same factors required for a BART determination.
The tables in the final Technical Support Document identify the emission units that are being controlled under the consent decrees and have been modified to reflect that emission reductions from these same units are expected under BART. Similar to the discussion
above for CITGO Petroleum Corporation , the tables in the final report were amended to reflect 90% control of NOx from the installation of SCR at the refinery’s FCCU.

In regard to the blowdown system and flares at the Exxon Mobil facility, the ExxonMobil consent decree requires that the facil ity develop and implement a flare minimization plan
, and construct and operate a flare gas recovery system. This source is also subject to the requirements of New Source Performance Standards, or NSPS, for petroleum refineries

### 16



### ( see , 40 CFR 60, Subpart Ja) that will require the use of flare gas recovery. These requirements will reduce SO 2 

### emissions significantly in the next few years, although in its final report, the Illinois EPA has not quantified the amount of reductions expected to

occur.

Section 4.1 .1.3 of the Technical Support Document indicates that Midwest Generation will install scrubbers at the Joliet and Will County plants by 2019. Likewise, Section 4.1.2.2 indicates that Dominion Kincaid will provide BART SO 2 

### controls to 0.18 lbs/mmBtu by Jan uary 1, 2017. These dates far exceeds the date by which BART controls must be in place, which is within five years after the State’s Regional Haze SIP is approved by EPA. 4 

### These dates should

be set earlier in time.

The Illinois EPA agrees that the timelines summarized in this comment are consistent with the agreements between Illinois EPA and the mentioned EGUs. The SO 2 

### emission limit for Dominion Kincaid has been revised in response to comments by the U.S. Fish and Wildlife
Service and the USEPA. Per the revised agreement, Dominion Kincaid will provide BART
SO 2 

### controls to meet an emission limit of 0.15 lbs/mmBtu by January 1, 2017. According to the Regional Haze rule, BART controls must be implemented within 5 years of USEPA’s approval of the St ate’s BART SIP. Since USEPA is unlikely to approve Illinois’ SIP prior to January 1, 2012, implementation of final controls by January 1, 2017
, at Dominion Kincaid and at City Water, Light, and Power is consistent with the requirements of the Regional Haz e rule. The Illinois EPA has demonstrated that emission reductions from units operated by Midwest Generation will be greater by 2015 than would have occurred by presumptive BART control levels, so even though additional control measures will not be comple ted until 2019, Midwest Generation meets its obligation under BART. The additional reductions provided by Midwest Generation will help to ensure reasonable progress toward improving visibility.

The following comments were submitted by the United States Department of Agriculture, Forest

Servic e :

We would like to take this opportunity to note some concerns we have with the approach taken to justify that these reductions are better than BART. The baseline emission reductions used to compare the alternatives to was based on presumptive BART levels t aken from the EPA BART guidelines. These levels were determined to be generally cost effective across the United States by EPA. Nevertheless source

- by

- source BART determinations could show that further

4 See 40 CFR Part 51, Appendix Y. The U.S. Environmental Protection Agency finalized its BART Guidelines on June

15, 2005, and published the preamble and final rule text in the Federal Register on July 6, 2005. The rulemaking
action added Appendix Y to Part 51, titled “Guidelines for BART Determinations Under the Regional Haze Rule.”

See Section V.

### 17



### reductions are feasible. Analysis by the National P ark Service suggests this is the case for some

units. This would mean that the baseline emission reductions are understated.

Illinois’ approach to meeting the BART requirement does not rely on source

- by

- source BART determinations, but is based on existing emission reduction requirements on both
BART and non

- BART units that far exceed the reductions that could be expected from implementation of BART controls on just subject

- to

- BART units. The Illinois EPA has used the presumptive BART control level s as a reasonable baseline from which to compare the benefits of the proposed alternative control program. It is conceivable that a source

by

- source BART determination could show that a lower baseline could have been
established for certain emission units , but the emission reductions that will be achieved by Illinois’ agreements greatly exceed the reductions that could be achieved by any reasonable determination of BART controls that could be applied at subject

- to

- BART units.

We are also concerned that Illinois compares the reductions from its alternative plans, which are

across both BART and non

- BART units, to those from only BART units. These are two fundamentally different groups of units. Non

- BART

- subject units that have cost effective

controls ide ntified by application of the statutory factors are subject to regulation under reasonable progress. Reasonable progress and BART are separate requirements of the SIP. If the alternative control program includes both BART and non

- BART units, it is approp riate that the baseline program it is compared to also includes BART and non

- BART units for which control determinations are individually made based on the statutory factors. The current comparison ignores the reasonable progress section of the regional h aze rules.

The State of Illinois consulted with other states in order to develop coordinated emission management strategies, as set forth under 40 C.F.R. § 51.308(d)(3)(i

- iii). The State of Illinois fully participated in the planning and technical develo pment efforts of the Midwest Regional Planning Organization (―MRPO‖), and as such, participated in the efforts of the MRPO to perform the required analyses for Class I areas located in other MRPO states. Accordingly, the State of Illinois has acted to ens ure that BART determinations and emission control strategies that encompass the long

- term strategy for Regional Haze provide adequate emission reductions to mitigate the impact of emissions from Illinois sources on affected Class I areas necessary for achi eving reasonable progress in each such
affected area s

. In fact, Illinois will achieve emission reductions that exceed the reductions identified as necessary for achieving reasonable progress by states with Class I areas.

The SIP notes that NO X 

### and SO 2 

### reduction requirements under the alternative program will be phased

- in beginning in 2009 through 2019. We note that the compliance deadline for BART emission limits is within 5 years after EPA approval of the SIP meaning that some units may be

outside th is timeline (e.g. Midwest Generation’s Joliet and Will County units).

According to the Regional Haze rule, BART controls must be implemented within 5 years of USEPA’s approval of the State’s BART SIP. Since USEPA is unlikely to approve Illinois’ SIP prio r to January 1, 2012, implementation of final controls on or before January 1, 2017
, is consistent with the requirements of the Regional Haze rule. It is noted

### 18



### that a later compliance date may still meet the requirement depending on the date of final
USEP A approval of Illinois’ SIP. The Illinois EPA agrees that the timeline for implementing full controls at some units extend s beyond January 1, 2017, especially at
Midwest Generation. The Illinois EPA has demonstrated that emission reductions from all subj ect

- to

- BART utilities, including Midwest Generation, will be greater by 2015 than would have occurred by presumptive BART control levels. The additional reductions provided beyond 2017 by Midwest Generation will help to ensure continued progress toward improving visibility.

The description of visibility impacts for the Dominion Kincaid facility on page 34 of the technical support document for BART does not match the numbers in the comparison t able 4.10.

Based on t able 4.10 visibility i mpacts appear to be greater (worse visibility) under the proposed alternative for Mingo and Hercules Glades (p. 35 TSD for BART).

Based on this comment, and similar comments from the U.S. Fish and Wildlife Service and the USEPA, the Illinois EPA and Dom inion revised their original agreement to achieve greater reductions of SO 2 

### at the Kincaid power plant. The original agreement between Dominion and the Illinois EPA required that SO 2 

### emissions be reduced at Kincaid from the
current rate of 0.46 lbs/mmBTU to a rate of 0.20 lbs/mmBTU by January 1, 2014, and to 0.18 lbs/mmBTU by January 1, 2017. In subsequent discussions, Dominion agreed to
further reduce SO 2 

### emissions at the Kincaid plant to a rate of 0.15 lbs/mmBTU, which meets the presumptive BART emissio ns limit. Dominion has also agreed to meet the NOx emission rate of 0.07 lbs/mmBTU, in accordance with the original agreement with Illinois EPA. This emission rate is considerably more stringent than the presumptive BART
emission limit of 0.10 lbs/mmBTU. The Illinois EPA has performed additional CALPUFF modeling to assess the visibility improvements of the revised agreement. The Illinois EPA’s modeling confirms that Dominion’s final control plan for the Kincaid facility will provide greater visibility improvements than the presumptive BART emission limits. The revised agreement and Illinois EPA’s modeling are described in Section 4.1.2.2 of the final Technical Suppor t Document for Best Available Retrofit Technology Under the Regional Haze Rule, AQPSTR 09

- 06, April 29, 2011.

There is a typographical error on page 18 of the TSD for BART “CALPOST was used to determine the number of days at each receptor that have at least a 1% degradation in light extinction (1/Mm) over background conditions, which is equivalent to 0.5 deciviews degradation.” Degradation of 0.5 deciviews is approximately equivalent to five percent degradation in light extinction over background condi tions.

The Illinois EPA agrees with this comment and has corrected the error.

We request that Illinois provide language in your SIP linking the Regional Haze and New Source Review programs, including continued FLM coordination between these programs. Currently

there is no mechanism in the SIP to ensure that the emissions from new s tationary sources or major modifications of existing sources will make reasonable progress toward the national

### 19



### visibility goal (40 CFR 51.307). This could be especially important for emissions from new sources that were not anticipated in 2018 emission in ventories. Please describe how new and expanded sources of air emissions will be reviewed to ensure they don’t jeopardize reasonable progress goals set by Class I Areas owner states.

The Illinois EPA has amended the Regional Haze State Implementation Plan for Illinois, AQPSTR 1 0

- 08
, May 10, 2011
, to address this issue. See

, Section 8.2. T he visibility impacts of such sources will remain under the purview of existing requirements unde r Prevention of Significant Deterioration (― PSD‖). See , 40 C.F.R. § 52.21. The Illinois EPA administers the PSD program in Illinois under authority provided by Section 9.1 of the
Environmental Protection Act , 415 ILCS 5/9.1 (2010), and a delegation agreement with the USEPA authorizing Illinois to enforce the Federal PSD regulations.

The reasonable progress analysis done by the MRPO determined that CAIR would be sufficient to achieve reasonable progress toward the visibility goa ls not that specific changes made by Illinois in your own State regulations would meet reasonable progress. Likewise, the MRPO analysis of CAIR does not address the effects of non

- electrical generating units (non

- EGUs).

In the Regional Haze State Implementation Plan for Illinois, AQPSTR 10

- 08
, May 10
, 2011, Figures 6.1 and 6.2 demonstrate th at emissions from coal

- fired electric generating
unit s (―EGUs‖) under Illinois’ control program will be lower than would result from th e C lean A ir I nterstate R ule in 2018 for both NO

x 

### and SO 2 

### . Section 7.0 of the SIP document

has been amended to include a summary of the analysis performed by EC/R Incorporated
entitled ―Reasonable Progress for Class I Areas in the Northern Midwest

– Factor Analysis
, ‖ dated July 18, 2007. Pertaining to non

- electric generating unit s, the final

document includes Figure 7.1 , which is a summary graphic of EC/R Incorporated data
from the Regional Air Quality Analysis for Ozone, PM 2.5 

### , and Regional Haze: Final Technical Support Document, April 25, 2008 ( see , Appendix B to the Regional Haze TSD ),

that shows that potential visibility improvement from control in sectors other than EGUs is very small.

Chapter 8 of the draft SIP does not address § 51.308 (d) (3) (ii):

“Where other States cause or contribute to impairment in a mandatory Class I Federal area, the State must demonstrate that it has included in its implementation plan all measures necessary to obtain its share of the emission reductions needed to meet the progress goal for the area.”

...

Section 8.0 of the Regional Haze State Implementation Plan for Illinois, AQPSTR 10

- 08
, May 10 , 2011, has been amended to provide information on other sources that have the potential to cause or cont ribute to visibility impairment and control programs that apply to

these sources. Also included is a l ist of ―on

- the

- books‖ c ontrol measures which are being implement ed in Illinois that will provide emission reductions from other point sources, mobile sources, and area sources. All of these control programs, along with the electric generating unit controls under the Multi

- Pollutant Standards and C ombined P ollutant

### 20



### S ta ndard under the Illinois Mercury Rule, 35 Ill. Adm. Code Part 225 , go b eyond Reasonable Progress Goals and help provide for the Uniform Rate of Progress goals being
met at Class I area s in the central and e astern United States

.

The Forest Service would l ike to commend you for referencing the State’s interagency developed Smoke Management Plan. Referencing the plan allows it to remain flexible allowing the State to continue to improve smoke management techniques while working with land management agencies

.

The U nited S tates E nvironmental P rotection A gency (“USEPA”) informed the Illinois EPA that Appendix C to the draft Technical Support Document for Best Available Retrofit Technology Under the Regional Haze Rule, AQ PSTR 09

- 06

, September 30, 2010

, was not adequate for submission under the Regional Haze State Implementation Plan.

The Illinois EPA has added additional provisions to Appendix C , which includes the relevant provisions of the Illinois Mercury Rule, 35 Ill. Adm. Code Part 225

. Accordingly, the following bolded Sections and subsections under Subpart B of Part 225 are being submitted to the USEPA for approval (non

- bolded provisions are included for context) : Section 225.233(a), (b), (e), and (g) [except for the term ―mercury‖] ; Section 225.291; Section 225.292(a), (b), (c), (d), and (e); Section 225.293(a), (b), and (c); Section 225.295(a), (b), (c), and (d); Section 225.296(a), (b), (c), and (e) [except for the term ―mercury‖]; a nd
225.A PPENDIX A. T he USEPA has already approved Subparts A, C, D, and E of 35 Ill.
Adm. Code Part 225. See , 40 CFR §52.720(c)(178) (2010).

### ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST, P.O. Box 19506, SPRINGFIELD, ILLINOIS 62794-9506

- (217) 782-21 13

217/782-2113 PAT QU1NN, GOVERNOR USA BONNETT, lNTERJM DIRECTOR

PERMITTEE JOINT CONSTRUCTION AND OPERATING PERMIT

Kincaid Generation, LLC

Attn: C. J. Saladino

4 Miles West of Kincaid on Route 104
Kincaid, Illinois 62540

Application No.: 09050022**Appl)~_0_.<:~.,~.g.~s** i qna,!)_ on : 

### ="" ....• =: Control Program ror DatE: Issued: J'une 24, 2011**~ocation:** I'Cincaid Generating 1.0. No.: 021814AAB

PiiLe Received: May 6, 2009 Mitigation of Visibility impairment

StatioTI, West of Kincaid on Route 104

Permit is hereby granted to the above-designated Permittee to CONSTRUCT and

OPERATE an emissions control program for Kincaid Units 1 and 2 (the affected units) for mitigation of visibility impairment, as described in the abovereferenced application. This Permit is subject to standard conditions attached

he.reto and the following special condition (s) :

1. Introduction

a. This permi-t approves an emission control program (Program) for the

affected units (i.e., Kincaid Units land 2, the two electrical generating units at the Kincaid Generating Station) that addresses

the role of their emissions in visibility impairment and regional
haze, as is required for the affected units by the federal Clean

Air Act, Section 169A, Visibility Protection for Federal Class I

Areas. Under the Program, the Permittee will reduce emissions of nitrogen oxides (NO

x ) from the affected units by operating the existing 8CR systems on the units on a year-round basis. The

Permittee will also reduce emissions of sulfur dioxide (802) from

the affected units by installing flue gas desulfurization technoloqy on the units. The affected units \.vill becorne subject

to stringent annual limits for their NO:,.; and S02 emission rates,
'which limits represent application of Best Available Retrofit Technology (BART) to the units.

b. This Program generally reflects limits for the NOx and S02
emission rates of the affected units that are recognized as BART

in an agreement between the Illinois EPA and Dominion Energy

Services as the operator, and the Permittee, as the owner of the

Kincaid Station (coJ,.lectively "Dominion"), "Memorandum of Understanding on NO

x and S02 Emission Reductions Reflective of'

Best Available Retrofit Technology for Kincaid Units 1 and 2

between the Illinois Environmental Protection Agency and
Dominion,
II February 3, 2009. The final limit for 30 2 emissions is

more stringent than the limit in this agreement, being the result

of further discussions between Dominion and the Illinois EPA following the public comment period held by the Illinois EPA on the "Regional Haze State Implementation Plan for Illinois."Page 2

c. This permit is federally enforceable, that is, it establishes

limits for the NO
x and 50 2 emission rates of the affected units that

are directly enforceable and permanent and that are not contingent

upon commencement of construction by the Permittee of additional

flue gas desulfurization technology for the affected units. This

is because the new limits for the affected units are legally required pursuant to Section 169A of the Clean Air Act and these

limits are practically enforceable. In addition, before this permit was issued, a draft of this permit underwent a pub1.i.c

comment period.

2. Emission Reduction Requirements Under the Program

a. NO
x Emission Reduction Requirements

Commencing March 1, 2013 and continuing thereafter, the annual

average NO

x emission rate of the affected units, combined, shall

not exceed 0.07 pounds per million British thermal units (mmBtu).

This limit shall apply on a calendar year basis (i.e., for the period from January 1st to December 31s·t of each year) except in 2013, when this limit shall apply for the period from March 1st through December 31, 2013.

b. 80 2 Emission Reduction. Requirements

i. In the years 2014, 2015 and 2016, the annual average 30 2 emission rate of the affected units, combined, on a calendar

year basis, shall not exceed 0.20 pounds per million Btu.

ii. Commencing January 1, 2017 and continuing thereafter, the

annual average 80 2 emission rate of the affected units, combined, on a- c'a'lendar year basis, shall not exceed 0.15 pounds per million Btu.

c. Compliance Methodology

Compliance with the limits in Conditions 2(a) and (b) shall be

determined by dividing the total amount of NO
x or 80 2 emitted by the

affected units during the particular compliance period, in pounds,
by the fuel heat input into the affected units during the period,

in million Btu, using data for the emissions and heat input

collected under the federal Clean Air Interstate Rule (CAIR) (or

any subsequent federal program addressing NO

x and S02 emissions of

electrical generating units that is a successor to CAIR). NO
x and

80 2 allowances under CAIR or any successor program shall not be

considered in determining compliance ,with these limits, provided

however that the transfer of such allowances associated with the

affected units is not restricted by this permit and nothing in this permit shall be considered to prohibit or restrict the ability of

the Permittee or Dominion to sell, trade or transfer 80 2 or NO
x allowances of any vintage owned, allocated to or earned by the

affected units.Page 3

3. Reporting Requirements under the Program

a. Progress Reports

For 2011, 2012 and 2013, the Permittee shall submit progress reports to the Illinois EPA that describe activities that it

undertook during the year to prepare for complying with the limits

in Conditions 2(a) and (b). These progress reports shall be

submitted by April 30 of the year following the calendar year addressed by the report.

b. Compliance Reports

Commencing with calendar year 2013 and continuing thereafter, the

Permittee shall submit annual compliance reports to the Illinois

EPA that provide the annual NO x and 80 2 emission rates of the

affected units, with supporting documentation, and address compliance with the emission limits in Conditions 2(a) and (b).

These compliance reports shall be submitted by January 31 of the

year following the year or period addressed by the report.

4. Coordination with Other Applicable Requirements

a. This permit does not affect other applicable provisions and requirements for the affected units, including the authorization to
operate the units generally provided by existing state operating permits for the units and the requirements set forth in those permits.

b. The Permittee may operate the SCR systems on the affected units on

a year-round**ba~;>is** pursuant to this permit, until authorization for

such operation is provided in a CAAPP permit for the source. This

condition supersedes Conditions 1 and 6(b) of the attached Standard

Conditions for Construction/Development Permits, which are not applicable to this permit.

c. The Permittee shall obtain a construction permit for installation

of the planned flue gas desulfurization equipment on the affected units, which application shall address whether installation of such equipment and ancillary operations would entail a modification of

the source.

If you have any questions on this permit, please contact Christopher Romaine

at 217/782-2113.

Edwin C. Bakowski, P.E. Manager, Permit Section

Division of Air Pollution Control

ECB:CPR:psj

cc: Region 2 Date Signed:

# ~"'/ / 

### ZU 

# /1STATE OF ILLINOIS

ENVIRONMENTAL PROTECTION AGENCY

DIVISION OF AIR POLLUTION CONTROL

P. O. BOX 19506 SPRINGFIELD, ILLINOIS 62794·9506



### STANDARD CONDITIONS FOR CONSTRUCTION/DEVELOPMENT PERMITS

ISSUED BY THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

------------ ··

.. 1

The following conditions are applicable unless susperseded by special condition (8).

4. The permittee shall allow any duly authorized agent of the Agency upon the presentation of credentials, at
reasonable tirnes:

a. to enter the permittee's property where actual or potential effluent, emission or noise sources are located or where any activity is to be conducted pursuant to this permit,

b. to have access to and to copy any records required to be kept under the terms and COnditions of this permit,

c. to inspect, including during any hours of operation of equipment constructed or operated under this permit,

such equipment and any equipment required to be kept, used, operated, calibrated and maintained under this permit,

d. to obtain and remove samples of any discharge or emissions of pollutants, and

e. to enter and utilize any photographic, recording, testing, monitoring or other equipment for the purpose of preserving, testing, monitoring, or recording a:qy activity, discharge, or emission authorized by this permit.

5. The issuance of this permit:

a. shall not be considered as in any manner affecting tbe title of the premises upon which the permitted

facilities are to be located,

b. does not release the permittee from any liability for damage to person or property caused by or resulting from

the construction, maintenance, or operation of the proposed facilities,

c. does not release the permittee from compliance with other applicable statutes and regulations of the United
States, of the State of Illinois, or witb applicable local laws, ordinances and regulations,

d. does not take into consideration or attest to the structural stability of any units or parts of the project, and

IL 532 -()226

APC 1136 Rev. 5/99 Printed on Recycled Paper 090--005e. in no manner implies or suggests that the Agency (or its officers, agents or employees) assumes any liability, directly or indirectly, for any loss due to damage, installation, maintenance, or operation of the proposed equipment or facility.

6. a. Unless a joint construction/operation permit has been issued, a permit for operation shall be obtained from

the Agency before the equipment covered by this permit is placed into operation.

b. For purposes of shakedown and testing, unless otherwise specified hy a speelal permit coudition, the equipment covered under this permit may be operated for a period not to exceed thirty (30) days.

7. The Agency may file a complaint with the Board for modification, suspension or revocation of a permit:

a. upon discovery that the permit application contained misrepresentations, misinformation or false statements

or that all relevant facts were not disclosed, or

b. upon finding that any standard or special conditions have been violated, or

c. upon any violations of the Environmental Protection Act or any regulation effective thereunder as a result of

the construction or development authorized by this permit.



# JSTATE OF ILLINOIS

ENVIRONMENTAL PROTECTION AGENCY

DIVISION OF**AI~'** POLLUTION CONTROL

P:O. BOX '19506

, SPRINGFIELD, ILLINOIS**62794-950~**

STANDARD CONDITIONS

FOR**OPERATI~G** PERMITS

May, 1993

The Illinois Envirorunental Protec;::tion. Act (Illinois Revised Sta'cuteB l Chapter 1039) 'g;rants thEf Environmental. Protection Agencyauthori ty to impose condi,tlons 'on

issues. 111-112, permits Section which, it.

The following conditions are' applicable unless superseded by special permit conditions (s)

.

1. The issuance' of this permit does not release the Permit'tee**'fr~m** ,compliance 'with s'ta'te and

federal regulations which are part of the Illinois State Implementation 'Plan, as well 'a.'3 with

ot:her applicable .stables and regulations of the United States ,or the, State ,of Illiiw·is or with: apPlicable lac'aT laws, ordinances and**regu~ations.**

2. The .Illinois EPA has' issued this permit based upon the information submitted by the, Permittee'

in the' permit applica'tion. Any misinformation,· false statemeri't or misrepte'sentation in the application shall ,be grou.nd for revocat,ibn onder 35T.11. Adin. Code 2,Ol.16?"_··

3. a. The Permittee shall not authorize, cat}se, direct or allow- any modification, as defined in

35 Ill.: Adm. Code.20J..102, of equipment, operations or**prac~i<;::eswhich** are .refIce-te.d in

the p'e.tmit application as submi·tted unless a new application or request for revision of

the**existihg~** permit is fiJ.ed with the 11linois EPA and unless a new permi.t or revision of

the exisU.ng permit (8) is issued, for such modification.

b. This permit only' covers emission

the indicated plan't location ($)

relocation! this permit is 'void permitted location(s) or _if all specified on the permit. sources and control equipment while physically present at
Unless t.h'h permit: specifically provides for equipment

for 'an item of equipment on' 'the day 'it is removed from. the equipment is removed, notwithstanding the ,expiration date

The Permittee shall allow any duly authorized agent of the Illinois EPA! upon the presentation
of credentials,- a't reasonable times;

a. To enter the Permittee! s property ',,;here actual or potential effluent, emiss,ion or noise

sources are located or where any activity is to be conducted pursuant to this permit;

b. To have access to and' to copy any records requ.ir:ed to be kept under the terms !;Ind
conditions O'f this permit;

c. To**inspect~** including during any hours of operation o:f equipment consi:ructed or operated

under this permit, such equipment and any equipment required. to' be kept, used, operated,
calibrated and maintained u'ndcJ: this permit;

d. To obtain and remove samples of any discharge or emission of**pollut::ant~;** and

c. '1'0 enter and utilize any photographic! recording,**testin~JI'** mani.t.oring or o,ther equipment:

for the purpose of presf::rving test.lng, moni taring or recording, 'any acti vi ty, .discharge o.r emission autho,riied by this pernii t.

a. Shall not be considered as in' any manner affecting the title of'

the permitted facilit.ies are- lqcated; 'rhe issuance 0:[ this perm'it;

S32-0224

161 Rev. March, 2001 the premise." upon which 

# I 

# I



# .--------- J**r:-~--,--,~-c"-'-'_~**
__ __ b. Doe,s' ,jlO,t. release. the Pe.rmittee .from any liability for 

### bj-?r resulting from ,the**co~struction,** maintenance, 

### or**";:,,."""~_._** .. damage- to person or property,_ 'C':iu$-ed operation of**,th~ facili~ies;.** 

ag'ents; or
t·o**'·da.ln~,ge,** .

c;.: Does, -no'tt'ake, into 'considera'tion or at'test to

### ~he structural stability of: -a!1Y'

### ~,rii't~ o( t,he project;' anq

d. ::;)n .ric;). manner implies or. suggests that the Illinois EPA (or its o.:eficers, '.'emplo'yees) assumes any liabilitYr. directl.y or: indirectly, for .any loss du:e

in$.tal'lat,.1,<?D y maintenance, or operation, of the proposed equipment or facility.,

B. The facilities cQvered'by this penrii.t s,hall be operated in such a mannE;:r that thedi$Pb'S<i1:'.of·,

. ai,r,. ,contaminants collected by the equipment shall no.t cause a violation of**th~** Ehvironmdnt'al":**~ro~~ction** Act or 'regulations promulgated thereunder.

7.

8.

9. 'J:'he Petinitte'eshall maintain all' equipment covered under this permit in such a manner', that**.~he** perfoL\Uance of 

### such equipment, shall no't cause a violation of the., Environmental Protection AQt 

### <?T rl3gulations' promulgated thereuner,.

The Permittee shall maintain a maipt.enance record on the premises, for each item", of air pollution control equiptnent. This records shall be made available 'to any agent of the

Environmental Protection, Agency at anytime during normal working, hours and/or operating, hou'rs,'

As a minimum, this 'rec'ord shall show the dates o-f performance and nature of prev.enta,tive
maintenance**aGtivities,~**

No person shall cause or allow continued operation duriIlg malfunction,**breakdo~n** or startup of ar.l;y erniss.ion· source or related air p611utiop control equipm.qnt 

### iet such operation would cause a viola,tion' of an: applicable emiss'ion standard Or permit, limitation. Sho1;i)..d a**Inalfurict.ion~** breakdown dr· staXlt'u'p occur-- which results in e,missions in excess' of any applj,cable. standard or penni t 'limi tation

v the· P13rmi ttee shall: '

a. Immediately report the incident to the Illinois EPA's. RegionaJ,-**Fie~<;:l,** Qffic'e by telephone, telegraph, or other method 'as constitutes the

altern q t.1,ve; smd shall comply' with aTl rea's'onable directives of t,he
respect to the incident; Operations Section

fastest· avaj,lable

Illinois EPAwifh

b. Haintain the following' records for a period of no less than t,ltJO (2) years:

i. Date and duration of rrialfunction, breakdown

t or startup,

ii. Full and detailed explanation of the cause,

iii. Contaminants emitted and an es"tj.+nate of· quantity of ewissions,

iv. Measures taken to minimize the amount of emissions during the**ma~function,** breakdown

or startup, and

v. Measures taken to ;r:educefuture occurrences and frequency of incidents.

10. If the permit application contains a compliance program and projec't completion schedule, the
Penni ttee sha'll submit a project completion status report wi thin thid::y {30'}' .days of any date specified Lo. the compliance program and project comple,t'ion schedule or'·at six month intervals,

which'ever i,s ·nibre**fr'e:quen~** ..

11. The
and Permittee shall submit an Annual Emission Report as required by 35 I] 1. Adm. Code 

# 201.302j**3~** I],l. Adm. Code Part 254_



## ----------------

28J.::,C

### ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST, P.O. Box 19506, SPRJNGFJELD,ILUNOJS 62794-9506

- (217) 782-21 13

217/782-2113 PAT QUINN, GOVERNOR LISA BONNETT, INTER1M DIRECTOR

PERMITTEE JOINT CONSTRUCTION AND OPERATING PERMIT

City Water, Light & Power, City of Springfield
l\ttn: P. J. Becker, Environmental Health & Safety Municipal Center Complex

800 Monroe Street Springfield, Illinois 62712

j1El'lication No.: 09090046**I.D.~:.:** 167120AAO 

### :0J?

..**2.JiC2:~"nt/s** De_sig.Q_ation: DatE:; Received: September 25, 2009**§~bi~c't:** Emission Reduction Program for Visibility Impairment**1).a~t.e_.Issued:** eTune 23, 2011

Location: 3100 Stevenson Drive, Springfield, Sangamon County

Permit is hereby granted to the above-designated Permittee to CONSTRUCT and

OPERATE an emissions control program for Dallman units 31 and 32 (the

affected Dallman units) and Lakeside Unit 8 (the affected Lakeside unit) for mitigation of visibility impairment, as described in the above-referenced application. This Permit is subject to standard conditions attached hereto

and the following special condition(s):

1. Introduction

a. i. This permit approves an emission control program (Program)

for the affected Dallman units (i.e., Dallman Units 31 and
32, the two older electrical generating units at the

Dallman Generating Station) that addresses the role of

their emissions in visibility impairment and regional haze,

as is required for the affected units by Section 169A of

the federal Clean Air Act, VisibiJity Protection for

Federal Class I Areas. Under: the Program, the Permittee

would reduce emissions of nitrogen oxides (NO

x ) and sulfur

dioxide (S02) from the affected units by enhancing the operation of the existing SCR system and flue gas desulfurization equipment on the units. The affected units

would become subject to stringent annual limits that

represent application of Best Available Retrofit Technology (BART) for the NOx and S02 emission rates of the units.

ii. This Program reflects limits for the NO
x and S02 emission

rates of the affected Dallman units that are recognized as
BART in an agreement between the Illinois EPA and City
Water, Light and Power, "Memorandum of Understanding on NO
x and S02 Emission Reductions Reflective of Best Available

Retrofit Technology for City Water, Light & Power Dallman

Units 31 and 32 and the Shutdown of Lakeside Unit 8 between

the Illinois Environmental Protection Agency and City of Springfield, Office of Public Utilities," August 11, 2009.

PRJNTED ON RECYCLED PAPERPage 2

b. To address the role of the emissions of the affected Lakeside

unit (i.e., Lakeside Unit 8, the newer electrical generating unit

at the Lakeside Generating Station) in visibility impairment and regional haze, this perrnit requires that this unit, which ceased operation prior to August 2009, never resume operation.

c. This permit is federally enforceable, that is, it establishes requi,rements that are directly enforceable and permanent and that

are not contingent upon commencement of construction by the

Permittee of additional emission control equipment for the**~ffected** units. This is because the new requirements for the

affected units are legally required pursuant to Section 169A of

the C.lean Air Act and are practically enforceable. In addition,

before this permit was issued, a draft of this permit underwent a public comment period, including an opportunity for a public hearing.

2. Emission Reduction Requirements for the Affected Dallman Units

a. NO

x Emission Reduction Requirements

i. In the years 2010 through 2014, the annual average NO

x emission rate of the affected Dallman units, combined, on a calendar year basis, shall not exceed 0.14 pounds per million British thermal units (mmBtu). This limit shall apply on a calendar year basis, i.e., for the period from January 1st to December 31st of each year.

ii. In the years 2015 and 2016, the annual average NO

x emission

rate of the affected Dallman units, combined, on a calendar

year basis, shall not exceed 0.12 pounds per nunB'tu.

iii. Commencing January 1, 2017 and continuing thereafter, the

annual average NO

x emission rate of the affected Dallman units, combined, on a ca1endar year basis, shal1 not exceed
0.11 pounds per rrmBtu.

b. S02 Emission Reduction Requirements

i. In the years 2012, 2013 and 2014, the annual average 80 2 emission rate of the affected Dallman units, combined, on a calendar year basis, shall not exceed 0.29 pounds per mmBtu.

ii. In the years 2015 and 2016, the annual average S02 emission

rate of the affected Dallman units, combined, on a calendar

year basis, shall not exceed 0.25 pounds per mmBtu.

iii. Cormrrencing January 1, 2017 and continuing thereafter, the

annual average S02 emission rate of the affected Dallman units, combined, on a calendar year basis, shall not exceed

0.23 pounds per mmBtu.Page 3

c. Compliance Methodology

Compliance with the limits in Conditions 2(a) and (b) shall be

determined by dividing the total amount of NO x or 50 2 emitted by

the affected Dallman units during the particular compliance period, in pounds, by the fuel heat input into the units during

the period, in million Btu, using data for the emissions and heat input collected under the federal Clean Air Interstate Rule
(CAIR) (or any subsequent federal program addressing NO

x and 30 2 emissions of electrical generating units that is a successor to CAIR). NO x and 80 2 allowances under CAIR or any successor program shall not be considered in determining compliance with these
limits, provided however that the transfer of such allowances

associated with the affected Dallman units is not restricted by

this permit and nothing in this permit shall be considered to prohibit or restrict the ability of the Permittee or the City of Springfield to sell, trade or transfer S02 or NO
x allowances of

any vintage owned, allocated to or earned by the affected units.

3. Reporting Requirements under the Program

a. Progress Reports

The Permittee shall submit a progress report to the Illinois EPA

that describes activities that it has undertaken in preparation

for complying with the .limits in Conditions 2(b). This report
shall be submitted by April 30, 2012.

b. Compliance Reports

Commencing with calendar year 2010 and continuing thereafter, the

Permittee shall submit annual compliance reports to the Illinois

EPA that provide the annual NO

x and 80 2 emission rates of the

affected Dallman units, with supporting documentation, and

address compliance with the emission limits in Conditions 2(a)

and (b), as applicable. These reports shall be submitted by

March 1 of the year following the calendar year addressed by the

report, except for the initial report, for 2010, which shall be

submitted by October 1, 2011.

4. Coordination with Other Applicable Requirements

a. This permit does not affect other applicable provisions and requirements for the affected Dallman units, including the

authorization to operate the units generally provided by existing

state operating permits for the units and the .requirements set
forth in those permits.

b. The Permittee may operate the SCR systems on the affected DaLLman

units on a year-round basis pursuant to this permit, until

authorization for such operation is provided in a**CAP~PP** permitPage 4

for the source. This condition supersedes Conditions 1 and 6(b)

of the attached Standard Conditions for Construction/Development Permits, which are not applicable to this permit.

If you have any questions on this permit, please contact Christopher Romaine

at 217/782-2113.

Edwin C. Bakowski, P.E. Manager, Permit Section

Division of Air Pollution Control

ECB:CPR:psj Date Signed: 

# -F

Z3 I 

# zo II

cc: Region 2

PJ Becker, CWLP, EH & S, 201 E. Lake Shore Dr., Springfield, IL 62712STATE OF ILLINOIS

ENVIRONMENTAL PROTECTION AGENCY

DIVISION OF AIR POLLUTION CONTROL

P. O. BOX 19506 SPRINGFIELD, ILLINOiS 62794·9506



### STANDARD CONDITIONS FOR CONSTIWCTION/DEVELOPMENT PERMITS
ISSUED BY THE ILLINOIS ENVIRONMENTAL PHOTECTION AGENCY

The Illinois Environmental Protection Act (Illinois Revised Statutes, Chapter 111·1/2, Section 1039) authorizes the

Environmental Protection Agency to impose conditions on permits which it issues.

The following conditions are applicable unless susperseded by special condition(s).

1. Unless this permit has been extended or it has been voided by a newly issued permit, this permit will expire o"n

year from the date of issuance, unless a continuous program of construction or development on this project has

started by such time.

2. The construction or development covered by this permit shall be done in compliance with applicable provisions of

the Illinois Environmental Protection Act and Regulations adopted by the Illinois Pollution Control Board.

3. There shall be no deviations from the approved plans and specifications unless a written request for modification, along with plans and specifications as required, shall have been submitted to the Agency and a supplemental

written permit issued.

4. The permittee shall allow any duly authorized agent of the Agency upon the presentation of credentials, at
reasonable times:

a. to enter the permittee's property where actual or potential effluent, emission or noise sources are located 01' where any activity is to be conducted pursuant to this permit,

b. to have access to and to copy any records required to be kept under the terms and conditions of this permit,

c. to inspect, including during any hours of operation of equipment constructed or operated under this permit,

such equipment and any equipment required to be kept, used, operated, calibrated and maintained under this permit,

d. to obtain and remove samples of any discharge or emissions of pollutants, and

e. to enter and utilize any photographic, recording, testing, m,onitoring or other equipment for the purpOBC of preservhlg, testing, monitoring, or recording any activity, discharge, or emission authorized by this permit.

5. The issuance of this permit:

a. shall not be considered as in any manner affecting the title of the premises upon which the permitted

facilities are to be located,

b. does not release the permittee from any liability for damage to person or property caused by or resulting from

the construction, maintenance, or operation of the proposed facilities,

c, does not release the permittee from compliance with other appli.cable statutes and regulations of the United States, of the State of Illinois, or with applicable local laws, ordinances and regulations,

d. doos not take into consi.deration or attest to the structural stability of any units or parts of the project, and

APC 166 Rev. 5/99 Printed on R'ecyded Paper 090·005e. in no manner implies or suggests that the Agency (or its officers, agents or employees) assumes any liability, directly or indirectly, for any loss due to damage, installation, maintenance, or operation of the proposed equipment or facility.

6. a. Unless a joint construction/operation permit has been issued, a permit for operation shall be obtained from

the Agency before the equipment covered by this permit is placed into operation.

b. For purposes of shakedown and testing, unless otherwise specified by a special permit condition, the equip·

ment covered under this permit may be operated for a period not to exceed thirty (30) days.

7. The Agency may file a complaint with the Board for modification, suspension or revocation of a permit:

a. upon discovery that the permit application contained misrepresentations, misinformation or false statements

or that all relevant facts were not disclosed, or

b. upon finding that any standard or special conditions have been violated, or

c. upon any violations of the Environmental Protection Act or any regulation effective thereunder as a result of

the construction or development authorized by this permit.



# I

._----------------------jSTATE OF I1JI,INOIS

ENVIRONMENTATJ pIWTEC'l'ION AGENCY

DIVISION DE' AIR' POLLOTIONCONTROI,**l?~O.** Boxi9506 .:
SPRINGFIELD, ILLINOIS 62794-950 1 6

STANDARD CONDITIONS

FOR

OPERATING PERMITS

May, 1993

'The Illinois Environmental Protec;:tion, Act (Illinois Revised Statu'tes, Chapter. 111':"'1/2" 1039) 'gr:-ants the" Envirbrunental Protect:i.on Agency authority to impose condit'ions onpe.rmi,ts

issues.

The following conditions are' applicable unless superseded by special permi,t conditions (s) • Section

which· it.

1. The issl.lance· of t,his permit does not x'elease the Permittee from ,compliance wi t11 s't-ate and

feder:al regulations which are pa,r:t of the Illinois State Impleinenta'U.on 'Plan, as ',-jell as with

othe.r.: applicable statiIes and regulations of the United States ,or the sta'te of I1linois or with**applicablE~** loc'al laws, ordinances and regUlations.

2. The ,Illinois EPA has issued this permit based lipon the information submitted by the, Permittee

in the permit a'pplication. Any rrii:sinformation, false statemeri;t' or mL:-irepre'sentation in the applicat,io'n shall be ground for revocation Hilder 35 "Ill. Ad.'u. Code**~Ol.16,6** ..

3. a." The Permittee shall not au'thorize, cause, direct or allow· any modification, as defined in

35 Ill. Adm. Code. 201.102;- of equipment, operations or pract:i'ces 'Nhlch are ref.lected in

the permit applic'ation as submitted unless' a new appli.cation 

### or request for revision 0"- the existJtlg pe'rm:lt is filed with the Illinois EPA and unless a new per'mit or ,revision of

the existing permit (s) is issued for such modif"icaU.on.

b. 'I'his per,mit only cdvers emission sources and "control equipment while physically present at
the indicated plant**location~($).** Unless**th~** permi,t specifically provides for equipment. relocation, this pe:rmi't is '\roid ['or an item of:- equiprilei1t on' the day ';Lt. is removed from the permitted J.ocation(s) or if all**equipment~** is removed, notwiths'l:anding the ,expiration date specified on the permit.

4. The Permittee shaLL allow any duly authorized agent of the Illinois EPA, upon the present.ation

of credent.ials,- a't reasonable times:

a. To enter the Permittee 1 s property where actual or**pot~ential** effluent., emission or noise

sources are located or where any activity is to be conducted pursuant to this permit;

b. To have acceSS ·to and to copy any records required to be kept under the terms and
conditions o'f this permit;

c. '.t'o**inspect~** including during any hours of operation of equipment const,ructed or oper:ated

unde'r this pe.l::-mit, such equipinent and any equipment required, to be kept, used, operated, calib.r;:lt:ed and maintain,".'d under this permit;

d. To obtain and remove samples of any discha.rge ox: emission of pollutants; and

8. To er'l.ter and utilize any photographic,

for the purpose of pn"serving

1 testing,

emission authorized by 'this permit. rec'ording, testing,. illonit,oring or o,ther equipment. monitoring or r:ecording'any act::i.vityl' ,discharge or:

5. The issuance of this permit;

a. Shall not be conside:r:ed as in any manner affecting the title o:E the premises upon vlhich
the pexmitted facilities ax:e located;

:L 532-"0224
,PC 161 Rev. March, 2001

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## b:y or resulting from the COllstruction, ma:intenanC8, or operation of the facilities;:

. ," ,:':",

.

Co Does .nol:take. into 'consideration or at'test to the structural 'stability 

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### unft:

of the t)rc)ject;' and

d .

. In ·no manner implies or suggests that. the Illinois EPA (or its o:t;ficers
r ','employees) assumes any liability, dire.ctly or indirectly, for any loss due·

i-nstal1at,i,0ri, maintenance, or operation, 6f the pJ:oposed equipment or facility".

6'. The. facil.i.t'ies covered by this permIt shall be operated in such a man,ner thai: the disposal'

air. contaminants, collected by the equipment shall not cause a violation of the**Ehvironroeht'al:~:** Protpction Act or regulations promulgated thereunder.

7 'J,'he Permitt:eeshall main'tain all' equipment covered under this permit in $uc!J. a manner} that the performance of such equipment, shall no't cause a violation of the:, Environmenta,.l Protectio'n: 'p.'ct <?T i'egulations promul'gatf..:d- thereuner.

8. The Permittee shall maintain a main-tenance record on the premises for each" item of air pollution control equii.)tnent. This records shall be made available to any agent 

# of 'the

Errviro.nmerl'tal Protection Agency at' any time during normalworki/lg, tours and/or operating. 

### hours.

As a minimum, this record shall show the dates of performance and na'ture of**pr.~e\(erita,t.iw;** maintenance acti vi ties,;'

9. No person shall cause or allot<1 continv.ed operation during malfunction,**breakdo~n** or sta:ctup of

any**e~ission'** SOUrce or related air pollutiop control equipment if such operation would cause a
violation of an: applicable. emiss'ion standard or permit limitation. Sno\lld a 'Inalfuriction,

breakdown dr, stant'u'p occur'- wh.icch results in emissions in excess of any applj,cable_ standard or permi t 'limitation, the, Pennittee shall;

.

a. IIflU1.ediat,ely report the incident to the Illinois**EPA'.~** Regional E'ielq.

Office by telephone, telegraph, or other method as constitutes the alternq;tive, i;md shall comply Hith all rea's'onable directive.s of the
respect to the incident; Operations Section fas,test' available

Illinois EPA with

b. Naintain the following recorcis for a period of no les,s than two (2) years:

i. Date and duration of malfunction, breakdown, or startup,

i1. Full and detailed explanation of the cause,

iii. Contaminants e,mit·ted and an est,i}nate of- quantity of e:rnissions,

iv. Measures taken to minimize the amount of emissions duririg the

or sta.rtup, and malfunction, breakdO\in 

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v. Measures taken to reduce

_ future occurrences and frequency of incidents.

10. If the permit application contains a compliance program and p:r:oject completion .schedule, the

Pe:uflittee sha'lJ. submit a project completion statu,s report within thirty (30)

. days of any date 

# I**spc~i.fied.** in the qompliarice progra.m and project -complet-ion schedule or--'cl't six month intervals,.

whichever ,is -nlore frequent
-. , .' ".

. 

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11. The Permittee shall submit an Annual Emission Report ,as req,uired by 35 Ill. )\dm,', Code 201',"30

.. 2.,' and 35 Ill. Adm. Code Part 25.4.**~------**

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