1

In accordance with the Regional Haze R ule (40 CFR 51.308(i)(3)), the Pennsylvania Department of Environmental Protection (DEP) is making available the comments received b y the Federal Land Managers on the draft proposed Regional Haze (RH) State Implementation Plan (SI P) revision, and the DEP’s responses to those comments. The following is a reproduction of a comment letter received b y the Department from the United States Fish and Wildlife Service (FWS) and the National Park Service (NPS), with DEP‘s resp onses inserted:

**U.S. Fish and Wildlife Service and National Park Service Comments Pennsylvania Draft Regional Haze Rule State Implementation Plan**  **August 2, 2010** On April 22, 2008, the Commonwealth of Pennsylvania (PA) submitted a draft Regional Haze Ru le State implementation plan (SIP), pursuant to the requirements codified in federal rule at 40 CFR 51.308(i)(2), to the U.S. Department of the Interior, U.S. Fish and Wildlife Service (FWS) and National Park Service (NPS). Shortly after receiving the dra ft SIP, the FWS and NPS Air Quality staff discussed concerns with the draft document during a telephone conference attended by PA Department of Environmental Protection (PADEP) staff. Subsequently , PA decided that the FWS and NPS concerns would be conside red and another draft document would be sent to FWS and NPS at a future date. We received the new draft on June 2, 2010. The FWS Branch of Air Quality and the NPS Air Resources Division staffs have conducted a substantive review of this most recent draft and our comments follow. We look forward to the PADEP response as per section 40 CFR 51.308(i)(3), and as alway s, we are willing to work with the PADEP staff towards resolving the issues discussed below. For further information, please contact Tim Allen (FWS) at (303) 914

- 3802 or Pat Brewer (NPS) at (303) 969

- 2153.

**Overall Comments 1.**  **Comment:** We commend PA for working with us to revise its April 2008 draft SI P to address man y of the original concerns identified by previous consultation with the FWS and NPS. There is significant improvement in this revised draft in comparison to the previous document. **DEP Response:** The Department appreciates the reviewer’s assessment that the Department made significant improvement in developing the revised draft proposed Regional Haze (RH) State Implementation Plan (SIP) revision

.2

**2. Comment:**  We continue to have concern over PA’s approach towards meeting the controls identified by

the Mid Atlantic Northeast Visibility Union (MANE

- VU) Ask (“Ask”). Although we appreciate the Commonwealth’s need to thoroughly review the effects of adopting additional major air qualit y controls, MANE

- VU

- generated progress goals are dependent on successful adoption and implementation of these controls. We believe that the Commonw ealth‘s contribution to the success of the “Ask” is critical to achieving success in the region. **DEP Response:** The Department inten ds to pursue the control strategies identified in the MANE

- VU “Ask” in accordance with Pennsylvania law

. P age 95 of the proposed RH SI P revision contains the following paragraph: “MANE

- VU identified emissions from 167 stacks at EGU facilities as having visibility impacts in MANE

- VU Class I areas that make controlling emissions from those stacks crucial to improving visibil ity at MANE

- VU Class I areas. MANE

- VU’s agreed regional approach for this source sector is to pursue a 90 percent control level on SO2 emissions from these 167 stacks by 2018 as appropriate and necessary . MANE

- VU has concluded that pursuing this level of sulfur reduction is both reasonable and cost

- effective. Table 10.4.4

- 1 below lists the EGU stacks in Pennsylvania identified on the list of 167 stacks in all of MANE

- VU, with their current and antic ipated controls, the permit status of the SO2 controls, and the anticipated SO2 emissions reductions achieved b y 2018.” Additionally , p age 97 of the proposed RH SI P revision states the following: “Based on the controls proposed, constructed and under construction in Pennsy lvania, the Department has concluded that at this time, the Department’s CAIR regulation constitutes a reasonable measure for EGUs in Pennsylvania. Therefore, consistent with the MANE

- VU ‘Ask’ Statement, the Department projects a 94.5% reduction in SO2 emissions from the EGUs listed above in Table 10.4.4

- 1 (or from alternative measures, as appropriate and necessary).” Also, page 120 of the proposed RH SI P revision states the Department has developed a proposed low

- sulfur heating and distillate oil regulation, in response to the MANE

- VU ‘Ask’ low

- sulfur fuel oil strategy

. The Environmental Quality

Board ( EQB ) adopted the Department’s proposed low

- sulfur fuel oil regulation at its July 13, 2010, meeting. The public comment period began on September 25 th and ends o n November 29 th , 2010. Addit ionally , the Department has revised the proposed RH SI P to address the status of the regulation development that pertains to the source categories considered in the Mactec Report (Appendix O)

. (Please s ee page 83 of the proposed RH SI P). These examples c learly indicate the Commonwealth‘s dedication to pursue the goals of the “Ask” in order to achieve success in the region.

**3. Comment:**  PA’s Reasonable Progress consists of “pursuing, as appropriate and necessary , the four goals of the “Ask” Statement”. We are concerned that commitments are only

to “pursue” emission reductions, and there is no commitment to an enforceable mechanism that would ensure that the Commonwealth achieves these emission reductions.3

**DEP Response:** Itis not the Department’s pra ctice to commit to adopting measures that must go through the notice and comment process under the Penns yl vania Air Pollution Control Act (APCA) . Furthermore, the EQB has the statutory authority to adopt regulations, not the Department. In addition to pl an approvals , regulations undergo the review of several advisory committees before EQB action, and undergo consideration b y the Independent Regulatory Review Commission (I RRC) as well as the standing committees of the General Assembl y after EQB considerati on. A commitment to adopt could nullify the value of a public comment and board review process. The Department intends to pursue these goals through the regulatory process in accordance with Pennsylvania law.

**4. Comment:**  We complement PADEP’s discuss ion of the five factors in the Best Available Retrofit Technology (BART) anal ys es. However, it was not clear how PADEP applied the results of those five steps in making its final BART determination because all of the BART determinations led to conclusions that no additional controls represented BART, even when the five factor analy sis led to results that have been accepted as BART b y many other states. No indications were given, nor could any be derived from the information presented, as to what level of cost and benefit, if any , would be acceptable as BART by PADEP. **DEP Response:** In making BART determinations for the sources subject to BART in Pennsylvania, the Department did not establish or utilize bright line thresholds for cost or for visibility

imp rovement. Instead, the Department employ ed an approach that considered the multiple BART Guideline factors. As a result, sources with a higher degree of potential visibility improvement from control would justify higher cost controls. Conversel y, only l ow cost controls would be justified for sources with a lower degree of potential visibility improvement. The BART determinations are consistent with the BART Guidelines.

**5. Comment:**  PA does not specificall y identify the inconsistency of using MANE

- VU based Reasonable Progress Goal calculations. These final runs are based on Clean Air Interstate Rule (CAIR) and MANE

- VU “Ask” control assumptions. These controls are presentl y not realized, nor are there commitments with implementation plans specified to accomplish these controls in the SI P. Therefore, more information should supplement the document that fully describes the uncertaint y and whether the Commonwealth or the Regional Planning Organization has an y efforts planned (or in progress) to minimize these uncertainties. Specifically addressing these future estimates with more specific projections in the Commonwealth’s 2013 mid

- term review is imperative. **DEP Response:** Plan approvals for controls at a p ermitted source are subject to the notice and co mment p rovisions under the APCA . A commitment to adopt controls could nullify

the value of a public comment and board review process. As stated in a previous response above , i t is not the Department’s practice to commit to adopting4

measures that must go through a public comment process. T he EQB has the statutory authority to adopt regulations, not the Department. In addition to plan approvals , regulations undergo the review of several advisory committees before EQB action, and under go consideration by the I RRC as well as the standing committees of the General Assembly after EQB consideration. The Department intends to re

- evaluate the projections of SO2 reductions due to CAI R and the “Ask” control assumptions at the time of Pennsylvania’s first periodic report to determine whether the predicted reductions are realized. The reasonable progress report will evaluate the progress made toward the reasonable progress goal for each Class Iarea located outside Pennsylvania that may be affected b y emissions from within Pennsylvania.
**Specific Comments Section 5.0, Baseline and Natural Conditions**  **Section 6.0, Monitoring Strategy 6.**  **Comment:** PA does not have Class I areas, but does list Class Iareas in the MANE

- VU and Visibility and Tribal Association of the Southeast (VISTAS) States to which air pollution emissions from PA’s sources contribute towards visibility impairment. It would be helpful to include a brief summary of IMPROVE data for the Class Iareas that PA influences for the 20% worst and 20% best d ay s. These data are available at the VIEWS website ( http://views.cira.colostate.edu/web/ ). Itis not clear if these data are present in section 6.2 that was omitted to reduce file size. It is also not clear if Section 6.4 is intended to meet the require ment to commit to future monitoring. **DEP Response:** Pages 23

- 24 of the proposed RH SI P revision include summary tables that display the IMPROVE data that shows baseline visibility for the 20% worst and the 20% best visibility

day s based on the five

- year average for 2000

- 2004, natural background visibility

for the 20% worst and the 20% best visibility day s, and the difference between baseline and natural visibility conditions for each MANE

- VU Class I area and for nearb y Class Iareas. The Department consid ers the IMPROVE monitors located at Class I areas in MANE

- VU to be representative of those Class I areas and the monitoring data from those monitors to be a reasonable basis for assessing progress toward the regional haze program goals . Section 6.2 that w as omitted to reduce file size contains photographic information about the MANE

- VU Class I area IMPROVE monitors, and will be inserted back into the proposed RH SI P revision for the public comment period. Section 6.4 describes additional monitoring inform ation the Department plans to use to improve its understanding of visibility impairment and to assess visibility

and fine particle pollution in the region

. Because there are no Class I areas located in Penns yl vania, a monitoring plan is not required under 40 CFR § 51.308(d)(4).5

**Section 8.0, BART 7.**  **Comment:** Due to the number of BART Sources in PA, the reviews were divided among the separate NPS and FWS Air Quality Offices. Please refer to Attachment 1 for the NPS BART review and Attachment 2 for the BART review of the sources done by FWS. As noted above, it was not clear to us how PADEP concluded what emission controls were feasible and cost

- effective, and those that were not. **DEP Response:** T he Department did not establish or utilize bright line thresholds for cost or for visibility

improvement i n making BART determinations for the sources subject to BART

. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in significant visibility imp rovement from controls would consequently justify higher cost controls. The Department maintains that a low $/ton control cost should not supersede an excessivel y high cost of visibility improvement . The Department does not believe that requiring additio nal controls on a BA RT source based solely on a high cost of visibility improvement for very small visibility

improvement, albeit a low $/ton control cost, is justified or appropriate

. **Section 9.0, Reasonable Progress Goals 8.**  **Comment:** PA and other MAN E

- VU states are using the modeled results for the “Ask” to set reasonable progress goals for 2018. It would be preferable to set reasonable progress goals based on the On the Books (OTB)/On the Way (OTW) assumptions. The MANE

- VU scenario is problematic b ecause it includes several control assumptions that are not reasonabl y OTW to implementation in the MANE

- VU, MWRPO (Midwest Regional Planning Organization), and VISTAS states. Most problematic is MANE

- VU’s choice to unilaterall y increase Electric Generati ng Unit (EGU) emissions in MRPO and VI STAS States without consideration of legally enforceable controls already in place in those States. Also of concern are the assumptions that MANE

- VU States will reduce SO 2 from non

- EGU sectors though low sulfur fuel r equirements by 2018 and that MWRPO and VISTAS States will reduce SO 2 from their non

- EGU sectors b y comparable amounts. These reductions are not in progress. PA needs to address this discrepancy in its discussion of Reasonable Progress, and it is good to read that PA will also be addressing the differences between reality and reasonable progress goals at the mid

- course review. The discussion PA supplied regarding the differences between the MANE

- VU and VISTAS control assumptions used in setting 2018 reaso nable progress goals was helpful. PA should discuss how uncertaint y i n the federal CAIR program could affect the reasonable progress goals for the affected Class I areas. Please clarify whether PA’s CAI R rule requires specific SO 2 and NO x reductions inde pendent of the status of the federal CAIR rule. **DEP Response:** The MANE

- VU “Ask” modeling scenario ensures that the modeled results are indicative of the agreed upon strategy by the MANE

- VU states that is reflected in the “Ask” statement. MANE

- VU account ed for emission controls alread y in place and emission controls that are not yet finalized but likely to achieve additional6

reductions b y 2018 in the “Ask” (bey ond on the way) emissions modeling inventory for 2018. The Department relied on technical anal y ses, including the modeling scenario, developed b y MANE

- VU to demonstrate that Pennsylvania’s emission reductions, when coordinated with those of other states and tribes, are sufficient to achieve the reasonable progress goals in Class Iareas affected by Penns yl vania’s emissions. The Department believes these modeled results are reasonable to achieve the reasonable progress goals in Class I areas affected b y Penns yl vania’s emissions. The Department has developed a proposed low

- sulfur heating and distillate oil regulation, in response to the MANE

- VU “Ask” low

- sulfur fuel oil strategy

. Pennsylvania has proposed a single strategy for the state. Pennsylvania is pursuing a strategy that is not less stringent than the outer zone strategy

and one that would me et the sulfur content emission limits listed above b y 2018. Please see the modifications to page 120 in the proposed RH SI P revision for the updated status of this low sulfur fuel oil regulation. CAI R has been remanded, but not vacated and remains in pla ce until replaced. Penns yl vania’s CAI R regulation will require emissions reductions prior to implementation of EPA’s Transport Rule (TR), when final. The proposed TR is the replacement rule to the remanded federal CAIR rule. EPA is expected to finalize the TR in mid 2011; EPA also anticipates promulgating a second TR at the same time and finalizing it in mid

2012.
**Section 10.0, Long Term Strategy 9.**  **Comment:** The Long Term Strategy Section is well written in that it defines the MANE

- VU “Ask” and the major contributions to visibility impairment. There is a good discussion of related regulations and enforcement actions that will result in substantive emissions reductions in the Commonwealth. Although PA has committed to address this in the mid

- course review, this SI P should still discuss the Commonwealth’s efforts to implement the low sulfur fuel strategy of the MANE

- VU “Ask”. We concur with PA’s assessment that prescribed fire is a comparatively small contributor to visibility

impairment in its geographic region and that residential wood smoke is the more important contributor. Does PA have plans to address residential wood smoke? **DEP Response:** The Department has developed a proposed low

- sulfur heating and distillate oil regulation, in response to the MANE

- VU ‘Ask’ low

- sulfur fuel oil strategy . Penns yl vania has proposed a single strategy for the state. Penns ylvania is pursuing a strategy

that is not less stringent than the outer zone strategy and one that would meet the sulfur content emission li mits listed above b y 2018. Consideration of the regulation is anticipated to proceed on a schedule in accordance with the Pennsylvania Regulatory Review Act, the Penns yl vania Air Pollution Control Act, the Commonwealth Documents L aw, the Commonwealth Atto rney s’ Act and the procedures established by the Commonwealth’s Environmental Quality Board and by the Department. The proposed RH SI P revisi on has been modified on page 120 to include the following: “ The EQB adopted the Department’s proposed low

- sulfur fuel oil regulation at its July

13, 2010, meeting. The public comment period began on September 25th and ends on November 29th, 2010. The proposed regulation would7

re duce the allowable sulfur content limits of commercial fuel oil to 15 parts per million ( ppm ) for Number (No. ) 2 and lighter commercial fuel oils and to 0.25% sulfur content by weight for No . 4 commercial fuel oil, and 0.5% sulfur content b y weight for No. 5, 6 and heavier commercial fuel oils beginning Ma y 1, 2012. ” This statement will be u pdated at the time of final SI P submittal to account for further progress. Regarding residential wood smoke, the proposed RH SI P revision has been modified on page 83 to include the following: “New indoor wood stoves in Pennsy lvania are regulated b y EPA’ s Residential Woodstoves NSPS. The NSPS for residential woodstoves was part of the area source inventory developed by

MANE

- VU to model the 2018 inventory

for are a sources (see page 106 of this SI P revision)

. A final

- form outdoor wood boiler (OWB) regulat ion was approved by the Commonwealth’s Independent Regulatory

Review Commission (I RRC) on August 19, 2010. The Department’s final

- form regulation would require EPA’s Phase 2 emission standards, including the particulate matter standard of 0.32 lb/MMBtu, f or all new OWBs in the Commonwealth manufactured after June 1, 2011.” This statement will be updated at the time of final SI P submittal to indicate publication date of the OWB regulation as a final regulation.8 **Attachment 1 To FWS/NPS Comments** 

**– Pennsyl**  **vania Draft Regional Haze SIP NPS Best Available Retrofit Technology Comments**  **General Comments 10.**  **Comment:** We complement PA DEP for the clarity of its discussions of how it applied the five factors in the BART analy ses in making its BART determinatio ns. However, it was not clear how PA DEP applied the results of those five steps in making its final BART determinations because all of the BART determinations led to conclusions that no additional controls represented BART, even when the five factor anal ys is led to results that have been accepted as BART by man y other states. No indications were given, nor could an y be derived from the information presented, as to what level of cost and benefit, if an y, would be acceptable as BART b y PA DEP. **DEP Respons e:**  The Department did not establish or utilize bright line thresholds for cost or for visibility

improvement in making BART determinations for the sources subject to BART. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in significant visibility improvement from controls would consequently justify higher cost controls. The Department maintains that for a BART determination, a low $/ton control cost should not supersede an excessively

high cost of very

low visibility

improvement.

**11. Comment:**  The core purpose of the BART program is to improve visibility in federal Class I areas, and BART is not necessarily the most cost

- effective solution. Instead, BART represents a broad consideration of technical, economic, energy , and environmental (including visibility improvement) factors. We believe that it is essential to consider both the degree of visibility improvement in a given Class Iarea as well as the cumulative benefits of improving vis ibility across all of the Class Iareas affected. There are several Class Iareas impacted by Pennsylvania’s BART sources. We believe that it is appropriate to consider both the degree of visibility improvement in a given Class Iarea as well as the cumu lative effects of improving visibility across all of the Class Iareas affected. The same metric should not be used to evaluate the effects of reducing emissions from a BART source that impacts only one Class I area as for a BART source that impacts multi ple Class Iareas. Also, evaluating impacts at one Class Iarea, while ignoring others that are similarly significantl y impaired, should not be done. Emissions savings from a source are benefits that will be spread well bey ond only the most

- impacted Clas s Iarea, and should be considered. While Pennsylvania presented data describing improvements to visibility at a specific Class I area that would result from the various control scenarios it investigated, the Commonwealth has9

not explained how it incorpor ated this information about impacts upon all Class Iareas into its BART decision. For example, Wy oming evaluated cumulative visibility improvement for both its BART and reasonable progress determinations

— following are excerpts from those Wyoming determin ations (with emphasis added):

• Visibility

impacts were addressed in a comprehensive visibility analy sis covering all three visibility

impairing pollutants and associated control options. The cumulative 3

- ye ar averaged visibility

improvement from the ba seline **summed across the three ClassI areas**  achieved with L NB with separated OFA, upgraded wet FGD, and FGC for enhanced ESP (Post

- Control Scenario A) was 1.070

_ dv from Unit 1, 0.199

_ dv from Unit 2, 1.068

_ dv from Unit 3, and 0.892

_ dv from Unit 4. 1

• V isibility

impacts were addressed in a comprehensive visibility analy sis covering all three visibility

impairing pollutants and associated control options. The cumulative 3

- ye ar averaged 98th percentile visibility improvement from the baseline **summed acro ss**  **all four Class I areas** achieved with LNB with advanced OFA, dry FGD, and a new fullscale fabric filter, Post

- Control Scenario A for each unit, was 3.558

_ dv from Unit 3 and 1.963

_ dv from Unit 4. 2

• Visibility

impacts were addressed in a comprehensive visibility analy sis covering three visibility

impairing pollutants and the associated control options. The **cumulative visibility improvement as compared to the baseline across Wind Cave NP and**  **Badlands NP** achieved with new LNB with OFA at the 30

- day limit of 0.23 lb/MMBtu (based on the 98th percentile modeled results) was 0.14

_ dv from each of the three units. The expected visibility improvement over the course of a full annual period would be even greater due to the annual BART limit that is based on 0.19 lb/MMBtu. 3

• Visibility

impacts were addressed in a comprehensive visibility analy sis covering all three visibility

impairing pollutants and associated control options. The cumulative 3

- ye ar averaged 98th percentile visibility improvement from the base line **summed across both Class I areas**  achieved with LNB with advanced OFA, wet FGD, and existing ESP with FGC (Post

- Control Scenario A) was 1.716

_ dv from Unit 1 and 1.934

_ dv from Unit 2. 4

• Visibility

impacts were addressed in a comprehensive visibilit y analy sis covering all three visibility

impairing pollutants and associated control options. The cumulative 3

- ye ar averaged 98th percentile visibility improvement from the baseline **summed across both Class I areas**  achieved with LNB with advanced OFA, up grading the existing dry FGD, and a new full

- scale fabric filter, Post

- Control Scenario A for Unit 1, was 0.996

_ dv. 5 Oregon considered cumulative benefits for the Boardman Power Plant SCR addition for reasonable progress: **Table 22: Visibility Modeling R esults (percent improvement)** 10

Total visibility

impacts (sum of 98th percentile for all Class Iareas) The BART guidelines recommend anal yz ing visibility improvement for the highest impacted Class I area with the assumption that any improvement in the worse impacted area would result in improvement in the lesser impacted areas. **However, since the Boardman Plant significantly impacts 14 Class I Areas within 300 kilometers, the**  **Department tried to include other parameters that would assess the significance of the improvements for all Class I areas impacted.**  **Therefore, the Department added**  **the number of Class I areas with impacts greater than 1.0 delta deciview, the total**  **delta deciviews for all Class I areas (98th percentile), and the average delta deciview**  **f**

**or all Class I areas (98th percentile).** As can be seen in Table 21, any one of the parameters is fairly representative of the other parameters perhaps with the exception of WFGD. Given these results, the Departme nt does not believe that adding additional parameters, such as total deciview day s, would result in any other conclusions and would probably just add confusion to the anal ys is (e.g., more day s of impacts than are in a year). Using the results of the visibility modeling, the cost effectiveness of the control technologies is recalculated by relating the costs to deciview improvement ( **Mt. Hood and all Class I areas**  ) as shown in the following 2 tables. 6 Pennsylvania has ignored the other Class I areas where a given BART source is also causing or contributing to visibility impairment. The dollar cost per increment of visibility improvement would be substantially lower if full consideration is given to all affected Class I areas that would benefit from emission reductions. While we recognize that EPA h as provided no guidance on this issue of assessing visibility benefits that would result in multiple Class Iareas when emissions are reduced from a given BART source, we commend Wyoming and Oregon for their initiative in addressing the issue. We also reco gnize that there is no “perfect” method for addressing cumulative benefits, but we firmly

believe that Pennsylvania must show how it considered the cumulative impact of the BART sources the affected Class I areas. We have suggested an approach to Penns yl v ania that is consistent with available information and with the approach used b y W yom ing and Oregon, and again request that Penns yl vania show how it has considered the cumulative benefits of potential BART reductions. **DEP Response:** The EPA’s Guidelines f or BART Determinations , Final Rule ( 40 CFR Part 51, July

6, 2005 ) do es not stipulate a requirement for a “cumulative” impact anal ys is from one BART source on multiple Class Iareas. Therefore , and as stated by the commentator, since EPA has provided no gu idance on the issue of assessin g visibility benefits that may result in multiple Class Iareas when emissions are reduced from a given BART source , the Department maintains that such an analy sis is unwarranted. The Department also maintains that requiri ng additional controls on a BART source to provide very

small visibility

improvements at multiple Class Iareas due to an apparent low $/deciview visibility

improvement cost is nether justified or appropriate. The s ummation of very

small delta decivi ews s erves the mathematical purpose of increasing the delta deciview value with respect to the $/delta deciview equation and thereb y11

lowering the apparent cost of controls per delta deciview , while not providing an y significant visibility improvement to an y of the affected Class I areas. The examples of BART source impacts described in the comment are examples of large deciview visibility impacts at many Class I Areas within 300 kilometers of the Wy oming and Oregon BART sources. Very small delta deciview value s from a BART source should not be summed to determine the cumulative effect on all lesser affected Class 1 areas

. EPA’s BART guidelines recommend anal yz ing visibility improvement for the highest impacted Class I area , with the assumption that any improve ment in the worse impacted area would result in improvement in the lesser impacted areas. The Department applied the guidelines for the determination of BART for the affected sources.

**12. Comment:**  Based upon our reviews of BART anal ys es across the U. S., we believe that cost

- per - deciview ($/dv) of visibility improvement is the most

- common and most

useful parameter for assessing the cost

- effectiveness of strategies to improve visibility in Class Iareas. Our compilation 7 of BART analyses across the U.S . reveals that the **average cost/dv proposed by either a state or a BART source is $13** 
**- $20 million**  , 8 with a maximum of almost $50 million/dv proposed by Colorado at the Martin Drake power plant in Colorado Springs. **DEP Response:** The Department agrees th at the cost per

- deciview of visibility improvement is the most

- common and most

- useful parameter for assessing the cost

effectiveness of strategies to impr ove visibility in Class Iareas, because the Regional Haze program was designed to improve visibility in Class Iareas , which is measured in deciviews. However, the Department did not establish or utilize bright line thresholds for cost or for visibility

improvement in making BART determinations. The Department considered all of the BART Guideline factor s, and determined that a BART source analy sis resulting in significant visibility improvement from controls would consequentl y justify higher cost controls . It should also be noted that the $/deciview cost in the example provided in the comment is an incr emental cost effectiveness rather than the average cost effectiveness.

**13. Comment:**  Comments on the BART determinations for individual facilities that are subject to BART follow. We are focusing our comments on the BART determinations for the cement and paper facilities because they have larger impacts than the other BART sources. (Also, Pennsylvania is the only state that has not proposed Selective Non

- Cataly tic Reduction (SNCR), or any additional controls, for all of its BART cement kilns.) We are a lso providing comments on some of the other BART sources. More detailed comments regarding our BART reviews follow. **DEP Response:** The Department notes that the baseline visibility impacts from the cement kilns in other states are significantly higher th an those from kilns in Pennsylvania. The total maximum 24

- hour visibility impact s, due to all pollutants for all BART sources at a facility , from the cement kilns in Pennsylvania range from 0.0008dv to 0.608dv. For each individual BART stack, the maximum 24

- hour12

visibility impact due to NO3 (nitrates) range from 0.03dv to 0.39dv. Therefore it was appropriate to require SNCR control sy stems as BART for the cement kilns in other states.13

**14 .**  **Comment: AK Steel Corporation, Butler Works**  BART 5 Factor Anal ys is: STEP

– 1: I dentify

All Available Retrofit Control Technologies **PA DEP:** Ultra low NOx burners is the available retrofit control option with the practical potential for application to the miscellaneous natural gas burners for the control of NOx. **NPS:** P A DEP should have included SCR in its analy sis for the annealing furnace. 9 STEP

– 4: Evaluate Impacts and Document the Results **PA DEP:** Cost of Compliance: Ultra Low NOx Burner $12,800/ton, the Annualized Cost is $520,000. These calculations are based upon information obtained from EPA’s AP42 Manual. The potential emissions reduction for this control was estimated to be 41 tons. **NPS:** PA DEP should better explain these estimates. **DEP Response:** Based on NESCAUM modeling results on A.K Steel facility ’s NOx em issions, the following are the visibility impacts on the Class 1 areas: Class Iarea Visibility I mpact due to all sources Visibility I mpact due to EAF Visibility I mpact due to remaining sources Shenandoah 0.041 dv 0.034 dv 0.007 dv Dolly Sods 0.035 dv 0.024 dv 0.011 dv Otter Creek 0.047 dv 0.036 dv 0.011 dv Total Visibility Impacts 0.123 dv 0.094 dv 0.029 dv
As acknowledged in the comment, there is no feasible NOx control technology for EAFs. As per AK Steel's submittal, the facility recent ly installed ULNB on two process furnaces. For the six processes that could utilize similar UL NBs the average cost would be $3.2 million dollars as per the AK Steel submittal to replace all of the burners. The NOx reduction from the installation of ULNBs at a 65% reduction would be 41 tons per ye ar as per the AK Steel submittal. AK Steel arrived at the 65% reduction factor b y comparing the uncontrolled and ULNB emission factors depicted in AP

- 42, Chapter 1, Natural Gas Combustion. AK Steel provided an explanation of their recent costs and the averaging process that they used to estimate their possible future costs on page 3 of their January 12, 2007 submittal. AK Steel provided the NESCAUM modeling results in Table 1 of their submittal. AK Steel provi ded the necessary source information for all of their sources in Table 2 of their submittal. AK Steel provided a cost summary estimation in Table 3 of their submittal. The Department concurs with the technical and cost analy sis that AK Steel provided. W hen summed the total existing deciview effect for the three Class 1 areas from AK Steel's remaining controllable sources is 0.029 deciviews. However, the Department does not believe that the thousandths of a deciview improvement that could be achieved at an y14

individual Class 1 area would provide true visibility relief, and that a summation is not warranted. AK Steel did not evaluate SCR as an option. SCR may be technicall y feasible, but it is not economicall y feasible. It is the Department's experience that SCR will ty picall y cost more than ULNB, usually at least 50% more. The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in si gnificant visibility improvement from controls would consequently justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class I area is considerabl y less than 0.5 dv, the threshold suggested in the BART Guidelines to determine if a source contributes to visibility impairment.

**15 .**  **Comment: Allegheny Ludlum Corporation, Brackenridge Facility**  STEP

– 4: Evaluate Impacts and Document the Results **PA DEP:** Cost of Compliance: (2) Ultra Low NOx Burner (fo r Loftus Soaking Pits): $12,800/ton, the Annualized Cost is $182,000. These calculations are based upon information obtained from EPA’s AP42 Manual. The potential emissions reduction for this control was estimated to be 14 tons. **NPS:** PA DEP should better e xplain these estimates. **DEP Response:** In its May 4, 2009 , “Review Memo for BART Application for the Alleghen y Ludlum Corporation Brackenridge Facility ”, the A lleghen y C ounty H ealth D epartment (ACHD) conducted an engineering analy sis under the BART determ ination process of 40 CFR 51.308(e) for each source subject to BART at Alle gheny Ludlum Brackenridge. The review memo was submitted to the Department as part of its BART submittal for Pennsylvania. The $12,800/ton estimated cost of Ultra Low NOx Burners is based on the costs associated with the recent installation of ULNB at a similar facility in Penns yl vania, the AK Steel Corporation, Butler Works, which recently installed UL

NB on two process furnaces. A 65% emission reduction factor for ULNBs was used in the ACHD calculation. This same number was used in the BART analy sis by the similar facility

in Pennsylvania noted above. As indicated by the PA DEP in its submittal for that facility , the number was derived from AP

- 42, Chapter 1, Natural Gas Combusti on. ACHD used the 65% reduction effectiveness figure to be consistent with the PA DEP use of that value in its AK Steel BART anal ys is. The $182,000 “Annualized Cost” is arrived at as follows: The value of the 2002 NOx emission inventory used in NESCAUM modeling for the Loftus Soaking Pits Numbers 9 through 23, and Numbers 43 through 46, is 21.9 tons per year. The NOx reduction from the installation of the UL

NB s is figured at 65% reduction factor, resulting in emissions reductions of 14.2 tp y. 14.2 tpy , at $12,800 per ton NOx removed, results in the $182,000 annualized cost ($181,760). The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is r esulting in significant visibility improvement from controls would15

consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is considerably less than 0.5 dv, the threshold su ggested in the BART Guidelines to determine if a source contributes to visibility

impairment.

**16 .**  **Comment: Appleton Papers Inc. /Spring Mill**  BART 5 Factor Anal ys is: STEP

– 1: I dentify

All Available Retrofit Control Technologies **NPS:** PA DEP is incorrect in omitting Flue Gas Recirculation as a NO X control option. 10 STEP

– 2: Eliminate Technically Infeasible Options **NPS:** PA DEP is incorrect in stating that wet scrubbing is technically infeasible due to the size of Power Boiler #3. While the size of the boi ler, and its emissions, will affect the economic feasibility

of installing a wet scrubber, it will not affect the technical feasibility . Georgia Pacific is installing a wet scrubber on Power Boiler #4 at its Big Island, Virginia, paper mill. Mead Westvaco is upgrading the wet scrubber on the power boilers at its Covington, Virginia, paper mill. STEP

– 4: Evaluate Impacts and Document the Results **PA DEP:** It was determined that the cost of control for this device was not cost effective considering the commens urate visibility improvement. Power Boiler #3 (SO2) Cost Effectiveness ($/ton) Cost of Visibility I mprovement ($/dv) $3,487/ton $51,200,000/dv **NPS:** PA DEP should better explain these estimates. STEP

– 5: Evaluate Visibility I mpacts **PA DEP:** The total decivi ew impact of this facility , including all BART eligible units, was modeled to be 0.089 dv. The cost in terms of dollars per deciview for installing a dry flue gas desulfurization sy stem at this facility was calculated to be $51,200,000/dv. Several control options were considered for SO2 control for the power boiler. The most cost effective means of control considered was an SDA sy stem. The resulting average cost effectiveness for installing the SDA s ys tem based on 2002 emissions was calculated to be $3,487/ton. The corresponding visibility improvement based on the installation of this technology over the baseline was estimated to be 0.048 dv. The cost of this control equipment in terms of visibility improvement was determined to be $51,200,000/dv. **NPS:** PA DE P should better explain these estimates. **DEP Response:** The Department received updated data from NESCAUM that modeled a 0.087 total deciview effect from Appleton's power boiler, 0.051 deciview from SO2 and 0.057 from NOx, with these numbers not adding up do to non

- linearit y of CAL PUFF modeling. In Appendix A of Appleton's August 2007 BART submittal they cited "Sargent and Lundy Dry Flue Gas Desulfurization; Costs for retrofit Units. Project 11311

- 000. 9/26/02." The levelized annual costs in Appleton's submi ttal came out to be $865,779. The Department calculates that at 100 % efficiency the $865,779 / 0.051 deciview = $16,976,450 per delta deciview. The actual delta deciview will be significantl y l ower than 100% depicted here. Appleton's power boiler burns a16

combination of coal, bark and sludge as does the No. 5 boiler at the Big Island, Virginia Georgia Pacific facility

that is referenced in this comment. BART control for this multi

- fuel boiler was determined to be limits on the % sulfur content of the coal and limits on the percentage of coal versus the total amount of other fuel burned. The effectiveness of FGD was deemed to be questionable because of the multiple fuels. The No. 4 Georgia Pacific boiler that installed wet FGD burns onl y coal. The No. 4 boiler is a 280 MMBtu/hr boiler where wet FGD is ty picall y used. The Appleton boiler is 180 MMBtu/hr where wet FGD is t ypically not used. The required BART efficiency on the Georgia Pacific boiler FGD is 90% which may be achieved by

dry FGD as Appl eton proposed for this evaluation. The Department concurs that FGR may be a technicall y feasible control option for a stoker boiler. However, the Department expects that a NOx cost analy sis divided by some fraction of the total 0.057 deciview effect will yi eld similar results as the SOx calculations shown here. The Appleton boiler alread y has over fired air for NOx control and through material balance has indicated an approximate 40% existing SO2 control rate. The Appleton facility has agreed to reduce their permitted allowable SO2 emission rate from 4.0 to 3.2 lbs/MMBtu. The Department proposes that these requirements represent BART for the Appleton Facility

especially

when the fact that only

a few hundredths of a delta deciview improvement could be ac hieved. The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in significant visibility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is less than 0.5 dv, the threshold suggested in the BART Guidelines to determine if a source contributes to visibility impairment.

**17 .**  **Comment: Essroc Cement Corporation**  Step 2

– Eliminate Technically I nfeasible Options. **PA DEP:** For Selective Non

- Catal yt ic Reduction (SNCR), ammonia or urea would be injected into the rotating kiln at a location where the gas is within the temper ature range of 1600 to 2000 Deg. F. On long kilns, this temperature may move along the axis of the kiln with time, causing injection to take place outside of the temperature range. SNCR has not been used full time on long wet or long dry kiln s ys tems. **NPS:** PA DEP is incorrect. As noted in our e

- mail of 9/07/07 to PA DEP, Ash Grove Cement has installed a full

- scale SNCR sy stem on one of its Midlothian, Texas, kilns and, according to Ash Grove, “is achieving a 35%

- 40% NO X reduction on a consistent basis.” 11 Step 3

– Evaluate Control Effectiveness of Remaining Control Technologies. **PA DEP:** Removal efficiencies of the technicall y feasible NOx control technologies range from 18% to 35%. **NPS:** PA DEP is incorrect. Both Colorado and Washington have proposed 40% NO x reductions for SNCR. Step 4

– Evaluate Impacts and Document the Results.17

**PA DEP:** The estimated cost of SNCR is $1,014 per ton of NOx removed. **NPS:** PA DEP should better explain this estimate. Step 5

– Evaluate Visibility I mpacts. **PA DEP:** The maximum visib ility improvement due to the most effective NOx control in the most affected Class Iarea (Shenandoah National Park) was 0.076 dv. The minimum cost of improvement was $7,494,026 annually per deciview. Therefore, PA DEP does not recommend any additional control of NOx as a result of the BART anal ys is. The current operating permit limitation for NOx emissions from Clinker Kiln Number 5 is 476 pounds per hour. 5. Conclusion: The estimated visibility improvement is too low and the cost of additional air emissio n control too high to warrant additional emission control to meet the BART requirements. Thus, this reviewer concludes that no additional emission control equipment for BART is warranted at this location. Therefore, the existing permit limits will meet the requirements for BART. **NPS:** PA DEP is the only state to date to conclude that SNCR is not BART for a cement kiln. The results for the four other cement kiln BART anal ys es that we have reviewed are summarized below: • Ash Grove has proposed to add SNCR at 35% control to its wet kiln in Montana City , MT. • Holcim has proposed to add SNCR at 30% control to its wet kiln in Trident, MT. • Colorado has proposed that CEMEX add SNCR at 40% control to its kiln near Ly ons, CO. • Washington Ecology

has proposed that LeFarge add SNCR at 40% control to its wet kiln near Seattle, WA. PA DEP has underestimated the effectiveness of SNCR and has provided no information on how it arrived at its cost estimates. Finally , even with these short

comings, the $1,014 per ton is low er than the $4,200/ton cost at L efarge (WA) and the $7.5 million per deciview cost is below the national average of $13 million/dv for NO X BART. **DEP Response:** The Department has recentl y finalized a statewide amended NOx control regulation for P ortland c ement kilns which is viewable here: http://www.pacode.com/secure/data/025/chapter145/subchapCtoc.html The Department projects that Essroc’s NOx emissions from kiln #4 will be reduced approximately

20% b y 2013 as a result of the amended P ortland cement kiln regulation

. The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, and determined that a BART sourc e anal ys is resulting in significant visibility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is less than 0.5 dv, the threshold sug gested in the BART Guidelines to determine if a source contributes to visibility impairment.18

**18 .**  **Comment: Lehigh Cement/York Operations**  Step 1

– Id entify

All Available Retrofit Control Technologies. **PA DEP:** Table 3 lists all available control technolog ies on the Lehigh\ York White Cement Kiln for control of SO2 and NOx. L ehigh Cement conducted ambient modeling and visibility anal ys is for the period 2001 through 2003 at Class 1 areas affected by this facility . Visibility improvement is based on the compan y anal ys is. **NPS:** PA DEP’s Table 3 is incomplete and does not include all of the eight NO X control technologies identified by L ehigh in its January

2006 BART anal ysis. We are especiall y concerned that PA DEP omitted SNCR, which has been proposed as BART by every cement plant outside of PA that is subject to BART. PA DEP should explain why it omitted this critical technology

. Step 2

– Eliminate Technically I nfeasible Options. **PA DEP:** SNCR has not been used full time on long wet or long dry kiln sy stems. **NPS:** PA DEP is incorrect. As noted in our e

- mail of 9/07/07 to PA DEP, Ash Grove Cement has installed a full

- scale SNCR sy stem on one of its Midlothian, Texas, kilns and, according to Ash Grove, “is achieving a 35%

- 40% NO X reduction on a consistent basis.” 12 **PA DEP:** It has been reported that SNCR has been proposed for NOx control as BART on a long cement kiln in the US. While there several technical issues associated with the installation of SNCR for long kilns, economic and impact anal ys es were performed for this control option. A NOx reduction of 35% was used for SNCR on long kilns based on the July

2006 ERG report to the Texas Commission on Environmental Quality . They

used this reduction since SNCR control on long kilns is considered Innovative and available data is limited. **NPS:** PA DEP is incorrect. Both Colorado and Washington have proposed 40% NOx reductions for SNCR. Step 4

– Evaluate Impacts and Document the Results. **PA DEP:** The estimated cost of a Cadence fan combined with a SNCR sy stem is $ 2,623 per t on of NOx removed and also determined to be Economicall y In feasible. The estimated cost of a Cadence fan s ys tem is $ 1,118 per ton of NOx removed. **NPS:** PA DEP failed to evaluate addition of SNCR without the Cadence fan sy stem. Conclusion: **PA DEP:** The estim ated visibility improvement is too low and the cost of additional air emission control too high to warrant additional emission control to meet the BART requirements. Thus, this reviewer concludes that no additional emission control equipment for BART is warranted at this location. Therefore, the existing permit limits will meet the requirements for BART. Step 5

– Evaluate Visibility I mpacts. **PA DEP:** The maximum visibility improvement due to the most effective NOx control in the most affected Class Iarea (S henandoah National Park) was 0.017 dv. The minimum cost of improvement was $ 10,606,000 annually per deciview, for lesser improvement. Therefore, Ido not recommend any additional control of NOx as a result of the BART anal ys is. The current operating permi t limitation for NOx emissions from the kiln is 8.2 pounds per ton of cement clinker produced.19

Conclusion: The estimated visibility

improvement is too low and the cost of additional air emission control too high to warrant additional emission control to m eet the BART requirements. Thus, this reviewer concludes that no additional emission control equipment for BART is warranted at this location. Therefore, the existing permit limits will meet the requirements for BART. **NPS:** PA DEP is the only state to date to conclude that SNCR is not BART for a cement kiln. The results for the four other cement kiln BART analy ses that we have reviewed are summarized below: • Ash Grove has proposed to add SNCR at 35% control to its wet kiln in Montana City , MT. • Holcim has proposed to add SNCR at 30% control to its wet kiln in Trident, MT. • Colorado has proposed that CEMEX add SNCR at 40% control to its kiln near Ly ons, CO. • Washington Ecology

has proposed that LeFarge add SNCR at 40% control to its wet kiln near Seattle, WA. PA DEP has not evaluated SNCR and has provided no information on how it arrived at its cost estimates. Finally, even with these short

- comings, the $10.1 million per deciview cost for the Cadence fan plus SNCR is below the national average of $13 milli on/dv for NO X BART. **DEP Response:** The Department has recentl y finalized a statewide NOx control regulation for portland cement kilns which is viewable here: http://www.paco de.com/secure/data/025/chapter145/subchapCtoc.html The Department projects that L ehigh Cement/York’s NOx emissions from their white cement kiln will be reduced approximately 30% by 2013 as a result of the amended P ortland cement kiln regulation

. The BAR T determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in significant visibility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is less than 0.5 dv, the threshold suggested in the BART Guidelines to determine if a source contributes to visibility impairment.

**19 .**  **Commen t:**  **P.H. Glatfelter Company** STEP

– 4: Evaluate Impacts and Document the Results **PA DEP:** Based on a series of inquiries this reviewer made about the basis of their BART analy sis, P.H. Glatfelter provided two revisions to their cost data and the basis20

of the ir cost calculations. Their most current cost anal ys is breakdown for the wet scrubber is in Table 4 of the third version of their cost anal ys is. **NPS:** The third version revisions cited above were not received by NPS until they

were requested on 7/28/10. Our review of those revisions has determined that PA DEP has overestimated the costs of wet scrubbing SO 2 from Power Boiler #1. The over

estimation results from several deviations from the OAQPS Control Cost Manual approach: 9 • PA DEP did not follow the Cost Manual in estimating installation costs. The Cost manual recommends multiplying the Purchased Equipment Cost (PEC) by 0.85 to estimate the Direct Installation Cost. Instead, PA DEP multiplied the PEC by a factor of 1.65. • PA DEP assumed a 10% interest rat e instead of the 7% rate recommended by the Cost Manual. • PA DEP estimated operating labor time at 3 hours/shift versus the 0.5 hours/shift estimated by

the Cost Manual. • PA DEP estimated maintenance labor time at 1 hour/shift versus the 0.5 hours/shift estimated by

the Cost Manual. • The solid waste generation rate used b y PA DEP is double the 8/17/2007 vendor estimate. As a result of these deviations from the Cost Manual, PA DEP estimated a Total Annual Cost (TAC) of $5.4 million and cost

- effectiveness = $1,667/ton of SO 2 removed. Our application of the Cost Manual (see electronic attachment) yielded a TAC = $3.6 million and cost

- effectiveness = $1,127/ton of SO 2 removed. STEP

– 5: Evaluate Visibility I mpacts **PA DEP:** The 98 th percentile deciview improve ment expected by the installation of a wet scrubber s ys tem on the Number 1 Power Boiler was found to be 0.219 dv. The cost in terms of dollars per deciview at this facility for the installation of the wet scrubber was calculated to be $24,545,196/dv. The 9 8 th percentile deciview improvement expected by

operating the Number One Power Boiler existing OEC y ear round was found to be 0.010 dv. The cost in terms of dollar per deciview for this control approach was calculated to be $41,629,300/dv. **NPS:** In addition to improving visibility at Shenandoah National Park (the Class Iareas used by PA DEP), a similar visibility improvement was modeled at Brigantine Wildlife Refuge. PA DEP did not model additional visibility improvements at Dolly

Sods and Otter Creek Wilde rness Areas which had visibility impacts about half of those at Shenandoah and Brigantine.) The cumulative benefits of reducing SO 2 from Power Boiler #1 would be 0.44 dv at Shenandoah and Brigantine, with additional benefits at Dolly Sods and Otter Creek. Conclusion: **PA DEP:** The cost effectiveness of installing a wet scrubber s ys tem for SO 2 control on Number 1 Power Boiler, taking into account visibility improvement, was $24,545,196/dv. The cost effectiveness of operating the OEC s ys tem y ear - round for NO x control on the Number 1 Power Boiler, taking into account visibility improvement,21

was $41,629,300/dv. This data, in addition to cost effectiveness values for emissions reduced and modeled visibility impacts, are shown in Table III. **NPS:** Using the Cost Manu al approach to estimate the cost of adding a 90% efficient wet scrubber to Power Boiler #1, the resulting cost

- effectiveness at Shenandoah National Park is $17 million/dv is which is lower than the $20 million/dv average cost

effectiveness for all of the S O 2 controls we have seen proposed as BART nationwide. When one considers the cumulative benefits of improving visibility at the four Class I areas modeled b y PA DEP, the cost

- effectiveness drops below $9 million/dv, which is less than half of the $20 milli on/dv average cost

- effectiveness for all of the SO 2 controls we have seen proposed as BART nationwide. We conclude that addition of a 90% efficient wet scrubber to Power Boiler #1 is BART. **DEP Response:** The Department explained on page seven of the BART review memo that a wall would have to be demolished and an addition would have to be built

. Additionally , an asbestos abatement program would be required to allow for the installation of FGD. The facility added these costs to the Direct Installation calc ulation by using a factor of 1.65 instead of 0.85. The Department visited the facility and agrees that these additional costs will be incurred and should be accounted for as additional direct installation costs.22

**Attachment 1 Footnotes**

1 DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION BART Application Analysis AP

- 6040 May 28, 2009 NAME OF FIRM: PacifiCorp NAME OF FACILITY: Jim Bridger Pow er Plant

2 DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION BART Application Analysis AP

- 6041 M ay 28, 2009 NAME OF FIRM: PacifiCorp NAME OF FACILITY: Dave Johnston Plant

3 DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION BART Application Analysis AP

- 6047 May 28, 2009 NAME OF FIRM: Basin Electric Pow er Cooperative NAME OF FACILITY: Laramie River Station

4 DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION BART Application Analysis AP

- 6042 May 28, 2009 NAME OF FIRM: PacifiCorp NAME OF FACILITY: Naughton Pow er Plant

5 DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION BART Application Analysis AP

- 6043 May 28, 2009 NAME OF FIRM: PacifiCorp NAME OF FACILITY: Wyodak Plant 6 DEQ BART Report for the Boardman Pow er Plant Updated December 19, 2008

7 See http://www.wrapair.org/forums/ssjf/bart.html

8 For example, PacifiCorp has stated in its BART analysis for its Bridger Unit #2 that “The incremental cost effectiveness for Scenario 1 compared with the baseline for the Bridger WA, for example, is reasonable at $580,000 per day and $18.5 million per deciview .”

9 EPA **ALTERNATIVE CONTROLTECH NIQUES DOCUMENT** 
**-- NO**  **X EM**  **ISSIONS FROM IRON AND STEEL MILLS**  At iron and steel mills, there are 2 SCR units in the U.S. An SCR unit is being used to control NO X emissions from a gas

- fired, radiant tube, continuous annealing furnace at a steel mini

- mill in th e United States. This furnace also has LNB's. Controlled emissions from this unit are about 33 ppm at 3 percent O 2 . A second SCR unit, currently under construction, will be used to control NO X emissions from an annealing furnace at an integrated steel plant in the United States. This furnace does not have LNB's. The unit has a guaranteed NO reduction of 90 percent.

10 **BEST AVAILABLE RETROFIT TECHNOLOGYAT NON**
**- EGU FACILITIES, April 19, 2010**  **WISCONSIN DEPARTMENT OF NATURAL RESOURCES** The Georgia Pacific Green Bay facility has a system of six boilers supplying pow er and electricity used in the manufacturing of consumer paper products. **Boiler B26 is a spreader stoker** 
**- fired unit manufactured by Babcock and**  **Wilcox installed in 1962.** It is a tw o drum, balanced draft furnace, with a maximum rated heat input capacity of 350 mmBtu/hr. Boiler B26 burns washed coal (eastern high and low fusion and w estern coals) and petroleum coke. After reviewing these potential options, the NO x control approach with the largest emission reduction potential for each boiler is a **combination of flue gas recirculation and over** 
**- fire air (FGR/OFA) for boiler B26**  and over

- fire air (OFA) for boiler B27 follow ed by

a full

- sized selective catalytic reduction (SCR) system for treating the combined flue gas of both boilers. [emphasis added]

11 Overland Park, Kan., October 27, 2008, Ash Grove Cement Company Earns Working for Cleaner Air Award from North Texas Clean Air Coalition, Ash Grove Is First Texas Cement Manufacturer to Receive Award.23 12 Over land Park, Kan., October 27, 2008, Ash Grove Cement Company Earns Working for Cleaner Air Award from North Texas Clean Air Coalition, Ash Grove Is First Texas Cement Manufacturer to Receive Award Recognizing Businesses That Do Their Share for Cleaner Air. Ash Grove’s Midlothian plant is the first Texas cement manufacturer recognized in the five

- year history of the program and received the award for the company’s successful efforts to control nitrogen oxide (NOx) emissions. Ash Grove’s Midlothian facility wa s one of the first wet process cement plants in the w orld to install Selective Non

- Catalytic Reduction (SNCR) technology to successfully control ozone forming emissions.24 **ATTACHMENT 2 To NPS/FWS Comments** 

**– Pennsylvania Draft Regional Haze SIP**  **FWS Com ments on Best Available Retrofit Technology (Section 8)** 

**General Comments 20**  **. Comment:**  No draft BART determination performed b y the Penns yl vania Department of Environmental Protection (PADEP) resulted in a recommendation that BART controls be implement ed on an y emission unit. PADEP stated in Section 8.5.2 of the Proposed Revision to the State Implementation Plan for Regional Haze (June 2010) that, “The Department did not establish or utilize bright line thresholds for cost or for visibility

improvement . Instead, the Department employ ed an approach that considered the multiple BART Guideline factors. As a result, sources with a higher degree of potential visibility improvement from control would justify higher cost controls. Conversel y, only low cost controls would be justified for sources with a lower degree of potential visibility improvement.” It seems that PADEP did not establish any objective criteria for determining the acceptability of a given control technology ’s cost effectiveness or cost of visibility improvement. The above PADEP statement would seem to imply that in the absence of absolute bright line thresholds, given all the BART sources in the State, visibility improvement at the relatively lowest cost facilities would result in BART controls at some subset of the BART

- eligible units. Using that premise, it would seem reasonable that, at a minimum, the following facilities would qualify

as the relatively lowest cost facilities for BART controls, in order of preference: Lehigh Cement

–Ev ansville Kilns #1 and #2 SNCR CEMEX

– Wampum Kiln #3 SNCR Carmeuse Lime Kiln #5 SNCR Carmeuse Lime Kiln #5 LNB Sunoco Philadelphia Refinery Process Heater 2H

- 3 ULNB CEMEX

– Wampum Kiln #3 Water Injection Sunoco Philadelphia Refinery Process Heater 2H

- 5 ULN B
It is interesting that in Pennsylvania (PA), NO x controls on cement plants came out high in the BART cost rankings. Nationwide, man y cement plants are controlling NOx from their kilns in their BART determinations, so in this sense if PA were to contro l NO x from its cement plant kilns, the Commonwealth would be consistent with the rest of the nation. Given the proximity of Class I areas to PA BART sources, many BART determinations showed the cost

- effectiveness of visibility improvement was relativel y e xpensive, even though the cost per ton of NO x or SO 2 controlled was, in our opinion, very reasonable. In judging cost

- effectiveness of a given control technology as defined under the EPA BART Guidelines 1 in Step 4 (cost per ton of NO x , SO 2 or particulate matter) and Step 5 (cost per deciview improvement), it is the position of the Federal25

Land Managers that if either of the cost

- effective measures are reasonable then there is sufficient justification for implementing the control technology

. **DEP Response:** The Department does not agree. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys i s resulting in significant visibility

improvement from control s would consequently justify higher cost controls. The Dep artment maintains that for a BART determination, a low $/ton control cost should not supersede an excessivel y high cost of very low visibility improvement.

**21 .**  **Comment:** It’s important to note that two facilities in PA (L ehigh Cement Company /Evansville and Glatfelter Pulp & Paper Mill) each have visibility impact on Brigantine National Wildlife Refuge and Shenandoah National Park of about 0.6 deciviews. Though PADEP concluded that cost per deciview of visibility improvement at one or the other Class 1 area exceeded what it considered reasonable for a single facility , deference should be given to the total impact on multiple Class 1 areas b y a facility

. In this particular case the additive cost per deciview improvement could bring a control technology

wi thin acceptable cost range, since cost per ton was already reasonable for several particular control technologies at these facilities. **DEP Response:** The EPA’s Guidelines for BART Determinations, Final Rule ( 40 CFR Part 51, July

6, 2005 ) does not stipulat e a requirement for a “cumulative” impact anal ys is from one BART source on multiple Class Iareas. Therefore, and as stated by the commentator, since EPA has provided no guidance on the issue of assessing visibility benefits that may

result in multiple Cl ass Iareas when emissions are reduced from a given BART source, the Department maintains that such an analy sis is unwarranted. The Department also maintains that requiring additional controls on a BART source to provide very

small visibility

improvements at multiple Class Iareas due to an apparent low $/deciview visibility

improvement cost is nether justified or appropriate. The summation of insignificant delta decivi ews serves the mathematical purpose of increasing the delta deciview value with respe ct to the $/delta deciview equation and thereb y lowering the apparent cost of controls per delta deciview , while not providing any significant visibility improvement to any of the affected Class I areas. Very small delta deciview values from a BART source should not be summed to determine the cumulative effect on all lesser affected Class 1 areas . EPA’s BART guidelines recommend anal yz ing visibility improvement for the highest impacted Class Iarea , with the assumption that any improvement in the worse impacted area would result in improvement in the lesser impacted areas. The Department applied the guidelines for the determination of BART for the affected sources.26

**22 .**  **Comment:** Appendix J contains all of the PADEP Review Memos , but the original compan y BART determinations should also be in the record. Please make these available in an Appendix. **DEP Response:** The Department is making the original compan y BART submittals available to the public upon request during the public comment period.

**23 .**  **Com ment:**  Please provide a discussion of how the five factors were used in making the BART determinations. Since there are so man y sources, a summary based on source category

may be sufficient with detailed information that could be included as an appendix. **DEP Response:** S ummaries of BART determinations by source categories do not convey the technical and detailed anal ys es the Department performed to make the BART determinations for each individual BART unit. The BART analy sis review memos convey

all the i nformation the Department relied on to make its determination s of BART, including how the five factors were used in making the BART determinations. T he Department’s review memos are included in Appendix J (relating to Pennsylvania’s BART anal ys is r eview m emos ) of the proposed Regional Haze (RH) State Implementation Plan (SI P) revision

.
**24 .**  **Comment:** On page 42, section 8.6, a large table lists BART eligible sources and their corresponding emission levels. It is not clear if these controls document exist ing levels or are implemented for BART. Please add a column that indicates whether these constitute new BART or existing controls. **DEP Response:** The Department modified the proposed RH SI P revision on page 58 ( relating to BART d eterminations, control le vels and s chedules ) b y including this statement: “ The Department proposes to determine that existing controls satisfy BART for the BART sources listed below in Table 8.6.”

**Refineries** PADEP has declared in the RH SI P that the Refinery consent decree controls represent state

- of

- the

- art

- control and that this level of control constitutes BART. **25 .**  **Comment:** Sunoco Marcus Hook Refinery It is noted that the 2.197 deciview impact at the Brigantine Wil derness Class Iarea (using the MM5 modeling platform) by this refinery is the largest visibility

impact of any facilit y in PA on a Class I area. The visibility improvement due to installation of the controls to be installed as part of the Environmental Protection Agency (EPA) Consent Decree (which is claimed to be BART) is not quantified. Please quantify this visibility improvement. The installation of Selective Cataly tic Reduction (SCR) on the27

Fluidized Cataly

tic Cracking Unit (FCCU) under the Consent Decree should provide for excellent visibility

improvement. In comparing the Review Memo dated September 25, 2007, to the Review Memo dated June 10, 2008, the control efficiency assumption for using Ultra Low NO x Burners (ULNB) on the process heaters went from 68% to 73%, respectively

. However, the cost per ton and cost per deciview improvement shown under STEP 4 on page 8 did not change. A pro

- rata calculation reflecting this change would show $8,532,138 per deciview improvement. This is not an unreasonable cost of visibility improvement. Also, the uncorrected $4,791 per ton of NO x control seems to be about double the amount of some other such installations. **DEP Response:** The Department agrees that the dollar/ton estimate should be adjusted to $4,462.00/ton for installation of UL NB. The annual cost will remai n at $316,919 / ye ar. Sunoco conducted modeling that predicted an approximate 0.035 delta deciview improvement from the installation of UL NB, maximum daily

impact scenario. $316,919 / 0.035 dv = $9,054,828.57.71/dv. In concurrence with the commentator, the Department maintains that compliance with the consent decree will achieve a significant visibility

improvement and further analy sis at this facilit y for BART is not warranted at this time.

**26 .**  **Comment:** United Refining Company In comparing the Revie w Memo dated September 25, 2007, to the Review Memo dated June 11, 2008, the only

difference is that the latter added a Table 3 showing the visibility impact at the Presidential Range to be about twice the impact at the Mingo Wilderness. However, cost per deciview improvement calculations went unchanged. It is, however, recognized that even a 2x reduction in the cost per deciview improvement would still result in very

high values and would not change the conclusion. The cost effectiveness figures for NO x control via Ultra Low NO x Burners at the Crude Heater are $3,266 per ton (PADEP 6/11/08 analy sis). This seems high when compared with the $750

- $1,110 per ton costs developed in Table 3

- 6 in the MARAMA Assessment of Control Technology Options For Petrole um Refineries in the Mid

Atlantic Region (January 2007). The reason for such a discrepancy should be explained. The Flue Gas Recirculation (FGR) alternative at $2,200 per ton of NO x reduction might be considered to be reasonable if PADEP would consider the cost per ton to supersede consideration of a high cost per deciview improvement, as discussed in the General Comments section above. **DEP Response:** The Department concluded in the review memo that if the 2 best feasible technologies were employ ed that a delta deciview of 0.00525 + 0.0046 = 0.00985 would be achieved at the worst affected Class 1 area. The Department concludes that this best achievable improvement would not be cost

- effective

. The28

BART determination is consistent with the BART Guidelines

. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in significant visibility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is considerably less than 0.5 dv, the threshold suggested in the BART Guidelines to determine if a source contributes to visibility

impairment.

**27 .**  **Comment:** Sunoco, Inc.

– Philadelphia Refinery Ultra Low NO x burners on Heaters 2H

- 3 and 2H

- 5 seem rea sonable on a cost per ton basis ($1,775 and 2,148, respectivel y) and the cost per deciview ($7.0MM and $8.5MM, respectivel y) is not considered as excessive. These controls should be implemented as BAR T. **DEP Response:** The Department concluded in the review memo that the impact benefit from Ultra Low NOx Burners at the worst Class 1 area would be a delta deciview of 0.0135 for the 2H

- 3 Heater and 0.0149 for the 2H

- 5 Heater. The Department concludes th at this best available achievement would be minimal. Additionally , the Department concluded in the review memo that compliance with a federally enforceable consent decree satisfies BART for the facility . This consent decree requires over 2,000 tons per y ear of NOx reductions from a 2001

- 2002 baseline from boilers and heaters at the facilit y through the installation of controls or shut downs. The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guidelin e factors, and determined that a BART source analy sis resulting in significant visibility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class I area is considerabl y less than 0.5 dv, the threshold suggested in the BART Guidelines to determine if a source contributes to visibility

impairment.

**28 .**  **Comment:** ConocoPhillips Trainer Refinery The Review Memo dated June 10, 2008 makes two references o n pages 3 and 8 to setting a NO x emission limit for the FCCU by May 2009. Since this date is past, the actual emission limit should be inserted or another date should be set. **DEP Response:** The Department agrees with the commentator. The BART table on pag e 58 and the discussion regarding consent decrees on page 103 in the proposed RH SI P revision have been modified to correctly describe the proposed final NOx limit s for the FCCU from the enhanced SNCR installed in 2006. EPA proposed final NOx limits fo r the Trainer FCC unit pursuant to paragraphs 50 and 51 of the referenced Consent Decree on January

5, 2010. Subsequently , ConocoPhillips (COPC) accepted EPA’s limits on August 5, 2010. Based on COPC’s acceptance of the NOx limits on August 5, 2010, COPC will act to incorporate the limits into a federall y enforceable permit29

pursuant to paragraph 257 of the referenced Consent Decree by November 2010

. The final FCC NOx limits are: 121.1 ppmvd (365

- day) and 155.3 ppmvd (7

- day).
**Electric Generating Unit s**  Pursuant to earlier comments by the Federal Land Managers , PADEP performed an additional BART anal ys is on behalf of most of the Electric Generating Units (EGU). This additional BART analy sis considered an Electrostatic Precipitator enhancement alternati ve, along with an objective visibility improvement anal ys is of cost per deciview, rather than rel ying on the subjective argument of “imperceptibility to the human ey e” of an y visibility improvement. The PADEP anal ys is lacked backup data/information and re ferences for arriving at the conclusions, but it could be argued that relativel y small adjustments to the supporting data would likely not result in a different overall outcome. **29 .**  **Comment:** The PADEP Review Memos for the EGUs (except for the Cheswic k P lant) generall y did not contain a final ‘Conclusion’ section as many other Review Memos did. We interpret the ‘Conclusion’ section as being a confirmation by PADEP management that the staff reviewer’s recommendation was accepted as PADEP findings and conc lusions. A more definitive statement by PADEP in Section 8.0 of the Proposed Revision to the State Implementation Plan for Regional Haze that all Review Memos are confirmed as PADEP conclusions could address this comment. **DEP Response:** The Department agr ees with the commentator. A ‘Conclusion’ section is a confirmation by the Department that the staff reviewer’s recommendation was accepted as the Department’s findings and conclusions. A statement was added to the BART Section 8.6 (relating to BART d eter minations, control levels and s chedules ) on page 57 of the proposed RH SI P revision to indicate that all review memos are confirmed as the Department’s conclusions.

**30 .**  **Comment:** Reliant Energy /Portland Generating Station The Company

conclusion is that BART is the existing electrostatic precipitator. BART for NO x and SO 2 is complying with requirements of the Clean Air Interstate Rule (CAI R). An assertion is made on page 1

- 1 that CAI R will also reduce emissions of sulfates/inorganic condensable PM 10 emi ssions. CAI R does not regulate sulfates and no further reductions will occur at this plant any way . **DEP Response:** While **t**he Department concurs that CAI R does not directly regulate sulfates , the SO2 reductions due to CAI R would reduce emissions of sulfates

.
**31 .**  **Comment:** Allegheny Energy Supply /Hatfield Station Units 1, 2, and 3 The Company

conclusion is that BART is existing control equip ment, which is an electrostatic precipitator (ESP) and an under

- construction Flue

- gas desulfurization30

(FGD) s ys tem. BART for NO x and SO 2 is CAI R. We commend Alleghen y Energy Supply and its environmental consultant, EnviroMet for developing a complete BART determination with dominant alternatives and a least

- cost envelope. It follows Appendix Y to Part 51

– Guidelines for BART Determinations Under the Regional Haze Rule

– better than any other anal ys is that we have reviewed for PA. The ESP Upgrade alternative of replacing T

- R Sets and Controls looks to be a reasonable selection for BART given the $1,734 cost per ton fi gure. The $39 million cost per deciview at Otter Creek Wilderness may be high, but if visibility

improvement at multiple Class 1 areas (i.e., Dolly Sods Wilderness, Shenandoah National Park and James River Face Wilderness) is considered, the cost of overal l visibility improvement warrants further consideration. **DEP Response:** The Depar tment has concluded that a maximum of 0 .006 delta deciview improvement due to an ESP upgrade at any one Class 1 area would not be cost

- effective

. Even with a cumulative maxi mum delta deciviews for all four Class 1 areas of 0.018 delta deciviews , ESP upgrade would be cost prohibitive for a BART determination,

**32 .**  **Comment:** PPL Generation LLC/Martins Creek SES Units 3 & 4 The Company

conclusion is that BART is the use of exi sting #6 Fuel Oils. BART for NO x and SO 2 is CAI R. Low annual capacit y factors of units (21% & 15%, respectivel y) result in large control costs on a per ton basis when examining ESP and venturi scrubber technology

. PADEP should develop emission limits comm ensurate with the low capacity

use, given that the lower emissions were used, in part, to evade emission controls. The assumption of only 80% control efficiency

for an ESP could be challenged with a more realistic 98% control efficiency , even though the C ompany made an argument for 80%. Nevertheless, it would not change the final conclusion that controls would be too expensive for the benefit. Neither the PPLGeneration BART determination nor the PADEP BART determination indicates that the facility is cl osed. However, PADEP indicated on the FLM BART consultation conference call that the fa cility was closed. This should be documented in the BART determinations and in the permit limits for this facility

. **DEP Response:** The Department meant to convey durin g the BART conference call the information that the coal fired boilers at Martin's Creek , Units 1 & 2, are permanentl y shut down. The oil fired boilers , Units 3 & 4, are still in operation and are operated at the limited capacities as noted.

**33 .**  **Commen t:**  Orion Power

– Cheswick Plant The PADEP Review Memo did not consider an upgrade to the existing ESP , but considered onl y the cost of a new baghouse. The EPA BART Guidelines 1 state that, “. . . y ou should consider way s to improve the performance of exis ting control devices, particularl y when a control device is not achieving the level of control that other similar31

sources are achieving in practice with the same device. For example, y ou should consider requiring those sources with electrostatic precipitators (ESPs) performing below currently

achievable levels to improve their performance.” **DEP Response:** The Department has concluded that removal of a small percentage of the maximum 0.03 deciv iew impact due to particulate matter at an y one Class 1 area wo uld not be cost

- effective.

**34 .**  **Comment:** Allegheny Energy

– Mitchell Power Station The reviewers did not locate a Compan y BART determi nation in the record. The PADEP Review Memo addressed the excessive cost of an ESP upgrade alternative. **DEP Respons e:**  The Department has concluded that a most maximum 0.001 delta deciview improvement at any one Class 1 area would not be cost

- effective . A copy of Alleghen y Energy's Mitchell Power Station BART submittal will be made available. The Mitchell Station has one 288 MW boiler that is subject to BART requirements.

**35 .**  **Comment:** Exelon Power

– Edd ys tone Generating Station The Exelon Power BART Evaluation document in section 5.5.1, and again on pages 9 and 10 of Appendix E, seemed to indicate that only one y e ar of meteorological data was used in the meteorological modeling. Section 3 of PADEP’s Review Memo seems to determine the visibility impact costs on a 98 th percentile basis. If onl y one year of meteorological data was used, visibility impact costs shoul d be based on the maximum 24

- hour impact, rather than the 98 th percentile value. We realize that the $141 million cost per deciview of improvement, even if modified by the above comment, would likely still be excessive. Nonetheless, it should still be co rrected. **DEP Response:** The Department concurs that the facility did use one y ear's worth of meteorological data , and revised the BART review memo to reflect the visibility impact costs based on the maximum 24

- hour impact

. **Cement Companies 36**  **. Comment**  **:** Lehigh Cement Company /Evansville Pennsylvania Facility PADEP’s conclusion is that BART for particulate matter is the existing control equipment, which is a fabric filter meeting the National Emissions Standards for Hazardous Air Pollutants requirements (commonly refered to as “MACT” standards). PADEP concludes that no additional control equipment is justified for NO x or SO 2 control. A Selective Non

- Cataly

tic Reduction (SNCR) sy stem for the combined NO x emissions from long dry

preheater Kilns #1 and #2 s hould be given more consideration as being cost

- effective. Certainly , the $627 per ton of NO x removal is reasonable. The32

$14,267,800 per deciview improvement as shown in Table 3a and 3b of the PADEP Review Memo for BART Application is not unreasonable in the context of visibility improvement costs undertaken b y some other BART determinations that have been made. Our most extensive information about the visibility costs of NO x control for BART come from electric generation units. There are man y instances of company

proposed BART NOx controls costing between $12 million and $35 million per deciview for visibility

improvement at a single Class Iarea. In addition, as discussed in the General Comments above, a cost of $14,267,800 per deciview of visibility improvement and $627 per ton of NO x control using SNCR for the Lehigh Cement

– Evansville plant is one of the lowest costs

- per - ton and visibility costs encountered among all of the BART determinations in PA. Therefore, if an y BART controls are to be undertaken in the State, SNCR at this plant should be one of them. An additional point should be made regarding visibility impact as measured by

the calculation of cost per deciview. We continue to believe that it is appropriate to consider both the degree o f visibility improvement in a given Class I area as well as the cumulative effects of improving visibility across all of the Class Iareas affected. It simply does not make sense to use the same metric to evaluate the effects of reducing emissions from a B ART source that impacts onl y one Class Iarea as for a BART source that impacts multiple Class Iareas. And, it does not make sense to evaluate impacts at one Class I area, while ignoring others that are similarl y significantly impaired. In this case, th e visibility improvement of deploying SNCR on Kiln #1 and Kiln #2 should be aggregated over both Shenandoah National Park and Brigantine Wilderness Area. Using Table 3

- 5 of Lehigh Cement Company ’s original BART determination (January

2006), the visibility improvement (in 98 th Percentile deciviews) of SNCR deploy

ment was shown as follows: Shenandoah Brigantine Kiln #1 0.02 0.04 Kiln #2 0.02 0.04 The result is a cumulative 98 th Percentile deciview impact du e to the deploy ment of a common SNCR on b oth units of 0.12 deciviews. If the $971,310 annual cost of SNCR is divided by

the 0.12 deciviews of visibility improvement, the result is $8,094,250 per deciview. This is well within a range deemed to be reasonable. **DEP Response:** The Department has re centl y finalized a statewide NOx control regulation for portland cement kilns which is viewable here: http://www.pacode.com/secure/data/025/chapter145/subchapCtoc.html The Department projects that L ehigh Cement/Evansville’s NOx emissions from kilns #1 and #2 will be reduced approximately 40% b y 2013 as a result of the amended P ortland cement kiln regulation.33

**37 .**  **Comment:** Lafarge Corporation/Whitehall Plant PADEP’s concl usion is that BART for particulate matter is the existing control equipment, which is a fabric filter meeting MACT, and that no additional control equipment is justified for NO x or SO 2 control. A Selective Non

- Cataly

tic Reduction (SNCR) sy stem for NO x emi ssions from the dry preheater Kiln #2 should be given more consideration as being cost

- effective. A cost of $1,804 per ton of NO x removal might be considered to be reasonable. The $27,177,065 per deciview improvement as shown in the PADEP Review Memo for BART Application is somewhat high, but in consideration of the discussion in the General Comment section above, a reasonable cost per ton might be cause to recommend that the technology

be deplo yed as BART, regardless of the cost per deciview. **DEP Respons e:**  The Department has recentl y finalized a statewide NOx control regulation for portland cement kilns which is viewable here: http://www.pacode.com/secure/data/025/chapter14 5/subchapCtoc.html The Department does not believe that requiring additional contr ols on a BART source based on a very

small visibility

improvement, albeit a low $/ton control cost, is justified or appropriate. The Department projects that L afarge’s N Ox emissions from kiln

- 3 will be reduced approximately

25% b y 2013 as a result of the amended P ortland cement kiln regulation. The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, an d determined that a BART source anal ys is resulting in significant visibility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is less than 0.5 dv, the threshold suggested in the BART Guidelines to determine if a source contributes to visibility impairment.

**38 .**  **Comment:** Cemex/Wampum Cement Plant Kiln #3 Cemex determined that it could commit to water injection and process controls for 7% NO x control and an as

- ye t undetermined technology for a 10% reduction in SO 2 . The Company admitted that this is not a “ty pical” BART analy sis and that CALPUFF modeling was not performed. Inthe absence of a full

- compan y BART determination, PADEP perfor

med a BART determination. PADEP concluded that SNCR at $1,014/ton NO x reduction and $4,678,401 per deciview of visibility improvement is too expensive and no additional control of NO x is warranted. The conclusion is incorrect. Both the $/ton and $/decivie w are within an acceptable range for BART and should not be dismissed

– especially

in the absence of an y state

- defined guideline as to what cost ranges are considered acceptable for BART, per our discussion in the General Comments Section above. Inadditi on, it seems that at a minimum, PADEP should34

accept the compan y’s BART offer to install the wate r injection technology for a 7% NO x reduction and an “as y et” determined 10% SO 2 control strategy , rather than concluding that no control technology is necessar y. **DEP Response:** The Department has recentl y finalized a statewide NOx control regulation for portland cement kilns which is viewable here: http://www.pacode.com/secure/dat a/025/chapter145/subchapCtoc.html The Department projects that Cemex’s NOx emissions from each of their three kilns will be reduced approximately 20% b y 2013 as a result of the amended P ortland cement kiln regulation. The BART determination is consiste nt with the BART Guidelines. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in significant visibility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is considerably less than 0.5 dv, the threshold suggested in the BART Guidelines to determine if a source contributes to visibility

impairment.

**39 .**  **Comment:** Key stone C ement Company

– Bath Facility It was stated in the Key stone BART Proposal (page 2

- 5) that the anticipated shutdown of Kiln 2 was to occur no later than 2009. This shutdown is a result of a newpreheater/precalciner kiln that Key stone is constructing. Howe ver, PADEP listed proposed emission limits for Key stone Kiln 2 in the listing of proposed emission limits for each BART facility

. Please confirm whether or not Kiln 2 has been shutdown, and, if so, the emission limits for Key stone Kiln 2 should be zero. The following discussion of SNCR for Key stone Kiln 2 may be mo ot if it is to be replaced b y a new kiln before the five ye ar BART deadline. A Selective Non

- Cataly tic Reduction (SNCR) sy stem for NO x emissions from Kiln 2 should be given more consideration a s being cost

- effective. A cost of $1,014 per ton of NO x removal might be considered to be reasonable. The $23,431,248 per deciview improvement as shown in the PADEP Review Memo for BART Application is somewhat high, but in consideration of the discussion in the General Comment section above, a reasonable cost per ton might be cause to recommend that the technology be deplo yed as BART, regardless of the cost per deciview. **DEP Response:** The Department has recentl y finalized a statewide NOx control regulat ion for portland cement kilns which is viewable here: http://www.pacode.com/secure/data/025/chapter145/subchapCtoc.html35

The Department does not believe that requiring addit ional contr ols on a BART source based on a very

small visibility

improvement, albeit a low $/ton control cost, is justified or appropriate. The Department projects that Key stone’s NOx emissions from kilns #1 will be reduced approximately

40% b y 2013 as a result of the amended P ortland cement kiln regulation. The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in significant visib ility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is less than 0.5 dv, the threshold suggested in the BART Guidelines to determin e if a source contributes to visibility impairment.

**Other Facilities 40**  **. Comment:**  Trigen

- Philadelphia Energy Corp./Edison Boiler #3 & #4 & Schuylkill Boiler #26 Trigen used a PADEP Reasonably Achievable Control Techn ology (RACT) benchmark limit of $1, 500 per ton of NO x as a bright line determination for judging the acceptability

of BART control technologies in section 2.2.2. This is contrary to a statement in section 8.5.2 of the draft Penns yl vania Regional Haze SIP which states, “The Department did n ot establish or utilize bright line thresholds for cost or for visibility improvement.” The $1,500 per ton cost would be within BART cost limits observed in national experience. The control effectiveness costs ($/ton) for various NO x control alternatives are well developed, but seem consistently higher than commensurate values shown in EPA AirControlNET. Please discuss an y differences or better document the references used to arrive at the stated costs. Lower, more reasonable costs could cause the Flue Gas Recirculation alternative to be a viable BART control. Trigen did not further consider wet scrubber s ys tems for SO 2 control as a BART alternative because it was not demonstrated in practice. Actuall y, wet scrubbing is successfull y deployed on oil

- fir ed boilers being operated in Japan, Cy prus and Korea. This should provide reason enough to perform cost anal ys is on this alternative. **DEP Response:** The Department did not use the $1,500 per ton of NOx proposed by Trigen as a bright line determination. The Department concluded in the review memo that the impact benefit from all controls for these units at the worst Class 1 area would be less than a delta deciview of 0.01 for NOx and less than or equal to 0.0123 for switching to ultra low sulfur diesel fu el for Boiler #26 and assuming 99% SO2 reduction. A wet gas scrubber would not have impact benefits that exceeded these levels. The Department con cludes that the best available achievements would be minimal.36

The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in significant visibility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is considerably less than 0.5 dv, the threshold suggested in the BART Guidelines to determine if a source contributes to visibility

impairment.

**41 .**  **Comment:** Carmeuse L ime, Inc./Annville Operation Lime Kiln #5 PADEP proposed that no additional equipment be installed on L ime Kiln #5 for NO x control, even though both low NO x burners (LNB) and Selective Non

- cataly tic Reduction (SNCR) are technicall y feasible and cost

- effective NO x control alternatives for a long dry

kiln. The Lafarge Cement Plant in Alpena, MI has proposed to install both technologies on five long dry kilns. Very

recently , the literature has begun to accept that SNCR is a technically feasible alternative for NO x control in long dry kilns. The most effective NO x control is SNCR at a cost of $1,014 per ton of NO x removed and $6,398,357 per deciview improvement at Dolly Sods Wilderness Area. LNB was shown to cost $1,318 per ton of NO x removed and $8,315,000 annually per deciview improvement. All of the above figures are within reasonable cost per ton and cost per deciview improvement ranges for BART. Therefore, these control technologies should be considered. The Portland Cement Association 2 noted that a relatively ine xpensive, but effective NO x control technique, is a ‘high pressure air injection sy stem’ (also called a mixing air sy stem) that can be installed on the kiln. Mixing air sy stems have shown significant emissions reduction up to 48% on the 13 kilns operating with this technology . This should have been considered among the BART NO x control alternatives. The proposed NO x emission limit of 6.0 lb NO x/ton of lime should be reconsidered if a NO x control technology

is accepted as BART. **DEP Response:** The Department has stated in the review memo that a maximum delta deciview improvement of 0.016 dv is all that would be achieved from the original 0.059 deciview impact at the worst case Class 1 area. The Department does not agree that such a minimal improvement wo uld be cost

- effective

. The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in significant visibility improvement from controls wo uld consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is considerably less than 0.5 dv, the threshold suggested in the BART Guidelines to determine if a source contrib utes to visibility

impairment.37

**42 .**  **Comment:** United States Steel/Clairton Coke Works Section 4 of the Review Memo stated that ACHD performed a BART analy sis and the results are presented in that document. However, the record does not contain the detail ed BART determination performed by ACHD on behalf of the Clairton Coke Works. Please provide this documentation in the record. Step 4 of the Review Memo states that annualized cost information was obtained from EPA’s AP42 Manual. The EPA BART Guidelines state that, “The basis for equipment cost estimates also should be documented either with data supplied by an equipment vendor (i.e., budget estimates or bids) or b y a referenced source (such as the OAQPS Control Cost Manual). Inorder to maintain and improve consistency , cost estimates should be based on the OAQPS Control Cost Manual , where possible. The Control Cost Manual addresses most control technologies in sufficient detail for a BART analy sis.” 3 You should assure that the cost estimates that were developed are accurate. Nevertheless, the cost per ton is very high, so minor changes in the costs will not likely change the final conclusions. In terms of cost per deciview improvement, please consider the effect on multiple Class I areas, rather than just Otter Creek, to determine the overall cost per deciview improvement. **DEP Response:** In its June 23, 2009 “Review Memo for BART Application for the United States Steel Corporation Clairton Works Facility ”, the ACHD conducted an engineering anal ys is un der the BART determination process of 40 CFR 51.308(e) for each source subject to BART at the Clairton Coke Works. Th e revi ew memo was submitted to the Department as part of its BART submittal for Pennsylvania. The details of the BART analy sis consist of what was presented in Section 4 of the review memo , under the Subheading “BART 5 Factor Analy sis,” and the following additional details are presented in this response to the comment: For the USS Clairton Works facility , Step 1 of the anal ys is identified Ultra Low NOx Burners (ULNBs) as the available retrofit control technologies for the sources identified as Boiler #2 and R1 Boiler. Steps 2 and 3 stated that ULNBs provide a 65% improvement over conventional natural gas burn ers. T he ACHD believes instead a value of 50% is a more appropriate emission reduction factor for use with the boilers under consideration. This is based on information found in AP

- 42, Chapter 1.4, “Natural Gas Combustion,” Table 1.4

- 1, which provides emission factors for Large Wall

- Fired Boilers greater than 100 MMBtu/hr, for Uncontrolled (Pre

- NSPS) boilers = 280 LB/10 6 scf, and Controlled

– Lo w NOx burners = 140 280 LB/10 6 scf, for a reduction factor of 50%. All of the boilers are larger than 100 MMBtu/hr and are pre

NSPS. In Step 4, the ACHD used a value of $12,800 per ton for the cost of ULNBs, the same value used for ULNBs in the anal ys is for another Allegheny County source (Allegheny Ludlum). In response to the comment, ACHD reviewed the Sixth Edition of the EPA OAQPS Control Cost Manual found at http://www.epa.gov/ttncatc1/products.html#cccinfo . H owever, information is only available for NOx post

- combustion controls, and information related to NOx38

combustion co ntrols, including low NOx burners, is identified as “ planned.” Therefore, ACHD utilize d the original $12,800 per ton figure for the cost of ULNBs. The “Annualized Cost” is arrived at as follows: For Boiler #2: The value of the 2002 NOx emission inventory used in NESCAUM modeling for the Boiler #2 is 290 tons per y ear. The NOx reduction from the installation of the UL

NBs is now figured at 50% instead of the previous 65% reduction factor, resulting in emissions reductions of 145 tpy. 145 tpy , at $12,8 00 per ton NOx removed, results in a $1,856,000 annualized cost for Boiler #2. For the R1 Boiler: The value of the 2002 NOx emission inventory used in NESCAUM modeling for the R1 Boiler is 8.8 tons per ye ar. The NOx reduction from the installation of th e UL

NBs is now figured at 50% instead of the previous 65% reduction factor, resulting in emissions reductions of 4.4 tpy . 4.4 tpy , at $12,800 per ton NOx removed, results in a $56,320 annualized cost for the R1 Boiler. Step 5, “Evaluate Visibility I mpact s” is now revisited: As before, using the CALPUFF NWS platform computer modeling the total visibility impact of this facility , including all BART eligible units, on the Otter Creek Clas s 1 area was found to be 0.0897 dv. The costs of possible new controls in terms of dollars per deciview for this facility were calculated to be: The impact of Boiler #2 on Otter Creek is 0.0605 deciviews. $1, 856,000/0.0605dv = $30,677,686/dv (instead of the previousl y calculated $39,775,000/dv ) for the ultra low NOx Burners for Boiler #2. The impact of the R1 Boiler on Otter Creek is 0.0017 deciviews. $56,320/0.0017 = $33,129,412/dv (instead of the previously calculated $43,144,000/dv ) for the ultra low NOx Burners for the R1 Boiler. The majority

of the visibility

impairi ng emissions are associated with the emissions from Boiler #2. The greatest visibility impact individually

was 0.0605 dv attributed to the NOx emissions from Boiler #2. The other emission source, the Desulfurization Plant, has existing controls. Based on a review of current emissions reduction approaches in the RACT/BACT/LAER Clearinghouse (RBLC) there does not appear to be adequate alternatives available for the Desulfurization Plant, bey ond the currentl y installed afterburner. Thus, no cost effectiv eness calculations were performed for SOx from this unit. 5. Conclusion: The conclusion is unchanged, even with the revised analy sis. Based on the five

- factor anal ys is, the impact of this facilit y does not warrant additional control. The Department c oncurred with the ACHD recommendation that c ompliance with the existing operating permits for this facility is BART

. The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, and determine d that a BART source39

anal ys is resulting in significant visibility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is considerably les s than 0.5 dv, the threshold suggested in the BART Guidelines to determine if a source contributes to visibility

impairment.

**43 .**  **Comment:** IS G Plate, LL C

– Coatesville Section 4 of the Review Memo stated that PADEP performed a BART analy sis and the resu lts are presented in that document. However, the record does not contain the detailed BART determination performed by the Department on behalf of the I SG Plate

– Coatesville Plant. Please provide that documentation in the record. PADEP should assure that the cost estimates that were developed are accurate as discussed above for the Clairton Coke Works. The cost per ton is very high, so relatively minor changes in the costs will not likely

change the final conclusions. Wet FGD for SO 2 control was anal yz ed in Step 3 of the Revie w Memo, but in Step 5 ‘dry ’ FGD is mentioned in the visibility analy sis. This very

possibly could be a ty pographical error. Wet FGD is capable of 98% removal, rather than the 90% assumed in the anal ys is, but again, even this chan ge would not likely change the final conclusions. In terms of cost per deciview improvement, please consider the e ffect on multiple Class I areas (i.e., Shenandoah National Park, Dolly Sods Wilderness Area and Otter Creek Wilderness Area), rather than jus t the Brigantine Wilderness Area, to determine the overall cost per deciview improvement. **DEP Response:** The Department reviewed the NESCAUM CAL PUFF data. As stated in th e review memo the maximum impact at the Brigantine Wilderness Area was modeled to be 0.055 deciview. This is the worst Class 1 area case. Of this, 0.022 deciview was attributable to NOx from the electric arc furnace. The Department concurs that there are no f easible controls for NOx for EAF s. The Department does not concur that contro l of some portion of the remaining 0.033 deciview would be cost

effective. The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in significant visibility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class Iarea is considerably less than 0.5 dv, the threshold suggested i n the BART Guidelines to determine if a source contributes to visibility

impairment.40

**44 .**  **Comment:** Sunoco Chemicals

– Frankford Plant The cost anal ys is for NO x and SO 2 control alternatives lacked detai l in constructing the basis for Total Capital Inve stment. This information should be provided to allow a third party

to check for reasonableness of the estimates. However, relatively minor adjustments to the NO x alternatives would not likely result in a change to the final conclusion that the alternativ es are too expensive. Inthe case of wet FGD for SO 2 control, $2,836 is not an unreasonable cost per ton of SO 2 removal, especially if a 98% control efficiency

were used rather than the 90% figure assumed b y the analy sis. Again, if PADEP is willing to all ow a reasonable cost per ton to supersede an excessively high cost of visibility

improvement, then the wet FGD alternative could be considered. **DEP Response:** The Department concluded in the review memo that the impact benefit from a wet FGD at the wors t Class 1 area would be a deciview improvement of 0.0301 for the boiler. The Department concludes that this best available achievement would be minimal. Since the baseline impact for the boiler is only 0.1379 deciview, an anal ys is using a control efficienc y of 98% would not result in a significant impact benefit. The BART determination is consistent with the BART Guidelines. The Department considered all of the BART Guideline factors, and determined that a BART source anal ys is resulting in significant vis ibility improvement from controls would consequentl y justify higher cost controls. The maximum modeled deciview impact due to this BART source on the most impacted Class I area is considerabl y less than 0.5 dv, the threshold suggested in the BART Guidelin es to determine if a source contributes to visibility impairment.

No comments were made on: Dy no Nobel, Inc. Nitric Acid Plant First Energy

Generation Corp

– Bruce Mansfield Plant PPLGeneration LL C

– Montour Exelon Power

- Eddy stone Generating Station

**ATTACHMENT 2 Footnotes**

1 See 40 CFR Part 51, Appendix Y. See Section IV.D.Step 3.4.

2 “Summary of Control Techniques for Nitrogen Oxide” by Zephyr Environmental Corporation for the Portland Cement Association, 2008, p. 2.

3 See 40 CFR Part 51, Append ix 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 IV.D.Step 4.a.5.41

In accordance with the Regional Haze R ule (40 CFR 51.308(i)(3)), the Pennsylvania Department of Environmental Protection (DEP) is making available the comments received b y the Federal Land Managers on the draft proposed Regional Haze (RH) State Implementation Plan (SI P) revision, and the DEP’s responses to those comments. The following is a reproduction of a comment letter received b y the Department from the United States De partment of Agriculture (USDA) Forest Service , with DEP‘s responses inserted:

**USDA Forest Service Comments Regarding Pennsylvania Draft Regional Haze Rule State Implementation Plan**  **7/30/2010** On June 2, 2010, the Commonwealth of Pennsylvania submitted a draft Regional Haze Rule State implementation plan (SIP), pursuant to the requirements codified in federal rule at 40 CFR 51.308(i)(2), to the USDA Forest Service (FS). The air program staff of the FS conducted a substantive review of the Pennsylvania draft plan, and have provided the comments listed below. We look forward to the Pennsylvania Department of Environmental Protection (PADEP) response as per section 40 CFR 51.308(i)(3). For further information regarding these comments, please contact Ralp h Perron at (802) 222

- 1444.
1. **Comment:** This draft Pennsylvania RH SIP has progressed nicely from its earlier version, however it still heavily relies on MANE

- VU work without clear specifics on Pennsylvania efforts. **DEP Response:** The Department apprec iates the reviewer’s acknowledgment of the Department’s progress in developing the proposed Regional Haze (RH) State Implementation Plan (SI P). MANE

- VU was formed by the Mid

- Atlantic and Northeastern states, tribes, and federal agencies to coordinate regi onal haze planning efforts and activities for the region as a group . MANE

- VU was formed to encourage a coordinated approach to meeting the requirements of EPA’s R egional H aze R

ule (RHR) and reducing visibility impairment in major national parks and wilderness areas in the Northeast and Mid

- Atlantic. With regard to MANE

- VU work and Penns yl vania efforts, the Department clearly and specifically

indicates Pennsylvania’s efforts throughout the proposed RH SI P as they

relate to the stated goals and emission man agement strategies and measures pursued b y the MANE

- VU regional planning organization to reduce the visibility

impairment in the Class Iareas of the Northeast and Mid

- Atlantic. For example, page 95 of the proposed RH SI P revision contains the following p aragraph: “ MANE

- VU identified emissions from 167 stacks at EGU facilities as having visibility

impacts in MANE

- VU Class I areas that make controlling emissions from those stacks crucial to improving visibility at MANE

- VU Class I areas. MANE

- VU’s agreed r egional approach for this source sector is to pursue a 90 percent control level on SO2 emissions from these 167 stacks by42 2018 as appropriate and necessary . MANE

- VU has concluded that pursuing this level of sulfur reduction is both reasonable and cost

- eff ective. Table 10.4.4

- 1 below lists the EGU stacks in Penns yl vania identified on the list of 167 stacks in all of MANE

- VU, (including for reference purposes and where applicable, the BART facility identification number associated with the stack modeled in the MANE

- VU Class Iarea deciview impact spreadsheets contained in Appendix I ) with their current and anticipated controls, the permit status of the SO2 controls, and the anticipated SO2 emissions reductions achieved by 2018 .” As is discussed further on p age 97 of the proposed RH SI P revision, the Department has concluded that at this time and based on the controls proposed, constructed and under construction in Pennsylvania, the Department’s CAIR regulation constitutes a reasonable measure for EGUs in Pennsylvania

. C onsistent with the MANE

- VU ‘Ask’ Statement, the Department projects a 94.5% reduction in SO2 emiss ions from the EGUs listed in Table 10.4.4

- 1 (or from alternative measures, as appropriate and necessary) by 2018

. Also, page 120 of the proposed RH SI P revision contains the statement that the Department has developed a proposed low

- sulfur heating and distillate oil regulation, in response to the MANE

- VU ‘Ask’ low

- sulfur fuel oil strategy . The Environmental Quality

Board ( EQB ) adopted the Departm ent’s proposed low

sulfur fuel oil regulation at its July 13, 2010, meeting. The public comment period began on September 25 th and ends on November 29 th , 2010. Additionally , the Department has revised the proposed RH SI P to address the status of the regu lation development that pertains to the source categories considered in the Mactec Report (Appendix O) . (Please s ee page 83 of the proposed RH SI P).

2. **Comment:** Overarching comment is that it remains very difficult to separate out how many facilities are in each category (EGU(CAIR), non

- EGU BART, 167 stack) and exactly which controls are being installed vs which are modeled, with associated reductions in NOx, SO2 and PM. For example, page 80: “Because of the SO2 controls installed in 2009 and 2010 ..., no additional measures will be needed to meet the reasonable progress goals.” Are these 167 stack controls operational now? Appendix I lists large deciview impacts from “RELIANT ENERGY NORTHEAS” on Dolly Sods and Otter Creek Wilderness, and while this fa cility is covered under the CAIR=BART umbrella, it is not clear what controls are anticipated for this facility (or other top contributors) or when they will be installed. **DEP Response:** The Department modified Tables 10.4.4

- 1 (relating to EGU s tacks in Pennsylvania and c ontrols i dentified from the MANE

- VU 167 s tack l ist ) and 10.4.4

- 2 (relating to additional EGU s tacks and c ontrols in Pennsylvania ) in the proposed RH SI P in response to the comment. The modifications indicate the permit status of the SO2 controls at the Pennsylvania EGU stacks listed in the two tables , and provide BART facility identification numbers associated with the stacks modeled in the MANE

- VU Class I area deciview impact spreadsheets contained in Appendix I(relating to MANE

- VU43 CAL P UFF m odeling r esults for Pennsylvania BART s ources ), where applicable, for eas y cross - reference . Table 10.4.4

- 1 now lists the EGU stacks in Pennsylvania that were identified on the list of 167 stacks in all of MANE

- VU, with their current and anticipated c ontrols, the permit status of the SO2 controls, and the anticipated SO2 emissions reductions to be achieved b y 2018. Table 10.4.4

- 2 provides similar information for several EGU stacks in Penns yl vania not identified on the MANE

- VU 167 stack list that the D epartment expects to be controlled as a result of the Department’s CAIR regulation.

3. **Comment:** Reasonable Progress consists of “pursuing, as appropriate and necessary, the four goals of the MANE

- VU ‘Ask’ Statement”. These are not insignificant, but are commitments to pursue, not enforceable reductions, yet. Also a four factor analysis was conducted (Appendix O “the Mactec Report”), but no controls adopted beyond pursuit of “ask” even though it appears that several sources categories have reasonable cost controls available. **DEP Response:** The Department is pursuing proposed regulations to address other source categories as described in Appendix O. The Department has revised the proposed RH SI P in response to the comment to address the status of the regulation development that pertains to the source categories considered in the Mactec R eport (Appendix O). (See page 83 of the proposed RH SI P). It is not the Department’s practice to commit to adopting measures that must go through a public comment pro cess. Furthermore, the EQB has the statutory authority to adopt regulations, not the Department. In addition, regulations undergo the review of several advisory committees before EQB action, and undergo consideration by the Independent Regulatory Review Commission as well as the standing committees of the General Assembly after EQB consideration. Plan approvals for controls as a permitted source are also subject to a public comment period. A commitment to adopt could nullify the value of a public comment and board review process.

4. **Comment:** Tables 7.2

- 1 and 7.3.1

- 1 show projected ~700,000 tpy of SO2 reductions under CAIR, yet there is no accounting for where these reductions will occur or if they are still projected to occur. Pennsylvania needs to en sure it has a mechanism to make the facilities operate at the required higher efficiencies, even if the market is not providing sufficient incentives. **DEP Response:** Table 7.2

- 1 (relating to Penns yl vania’s 2002 e missions i n t ons p er y ear) summarizes the P ennsylvania emissions , including emissions from stationary point sources, for 2002. Table 7.3. 1

- 1 (relating to Penns yl vania’s 2018 p rojected e missions ) summarizes the projected emissions , including emissions from stationary point sources, in 2018 for Penn sylvania sources . Comparing the SO2 totals for stationary point sources for 2002 and 2018 shows an approximate reduction in SO2 from all stationary point sources of 700,000 tons per y ear. These reductions are projections from all stationary point source44 sectors, and not solel y from the CAI R

- affected electric generating units (EGUs) in Pennsylvania. T he Department has concluded that at this time and based on the controls proposed, constructed and under construction in Pennsy lvania, the Department’s CAI R r egulation constitutes a reasonable measure for EGUs in Pennsylvania . C onsistent with the MANE

- VU ‘Ask’ Statement, the Department projects a 94.5% reduction in SO2 emiss ions from the EGUs i dentified from the MANE

- VU 167 s tack l ist , or from alternative meas ure s, as appropriate and necessary, b y 2018

. The Department is relying on implementation of EPA’s CAI R replacement rule, the proposed Transport Rule, for achieving the longer

- term (2015

- 2018) SO2 reductions from the EGUs. The Department intends to re

- eva luate the projections of SO2 reductions due to CAI R at the time of Pennsylvania’s first periodic report to determine whether the pred icted reductions are realized.

5. **Comment:** It would be helpful to include a summary of the non

- EGU BART determinations a s was in the previous draft. **DEP Response:** The length y summaries of BART determinations by source categories contained in previous RH SI P drafts d id not convey the technical and detailed anal ys es the Department performed to make the BART determinations f or each individual BART unit. The BART analysis review memos convey all the information the Department relied on to make its determination s of BART, and the review memos are included in Appendix J (relating to Pennsylvania’s BART analy sis r eview m emos )

.

6. **Comment:** There is still no demonstration that Pennsylvania is doing its share of emissions reductions at non MANE

- VU class I areas. **DEP Response:** The measures described in the proposed SI P revision demonstrate that the Department is pursuing the adop tion and implementation of emission management strategies to obtain its share of emissions reductions at the MANE

- VU Class I areas and the non

- MANE

- VU Class Iareas. Shenandoah National Park in Virginia and the Dolly Sods/Otter Creek Wilderness Area in We st Virginia are Class I areas in the Visibility Improvement State and Tribal Association of the Southeast (VISTAS) region that are impacted b y emission sources operating in Pennsylvania and other MANE

- VU states. The Department consulted with the planning staff in West Virginia and Virginia when they were establishing their reasonable progress goals for the Class I areas in their states. Neither of these two States intends to request that Penns yl vania make additional reductions at emission sources located in Pennsylvania (see page 19 of the proposed SI P revision). The most recent modeling completed b y VISTAS for the Class I areas in VI STAS showed the uniform rate of progress in 2018 would be met at both45 Shenandoah and Doll y S ods. VI STAS modeling results indicate that the projected level of emissions controls for Penns yl vania’s sources by 2018 will allow the Shenandoah National Park and Doll y Sods Class Iarea to meet the reasonable progress goals established by Virginia and West Virginia, respectivel y, b y 2018. The emissions control strategy for the MANE

- VU Class I areas’ reasonable progress anal ys is is , therefore , a reasonable emissions control strategy

for the reasonable progress analy sis for the Shenandoah National Park and Doll y Sods Class Iareas. ( Please see page s 64

- 66 of the proposed SI P revision for the complete discussion.)

7. **Comment:** Pennsylvania contains many stationary area sources related to oil and gas development and long term operation. This should be addressed, at a minimum, on pages 33

- 34 (Section 7.3.2, Stationary Area Sources) along with dry cleaners and service stations. **DEP Response:** The development and operation of oil and gas reserves in Pennsylvania requires stationary area sources (mostly stationary internal combustion engi nes) and non

- road engines located at oil and gas sites. Stationary

internal combustion engines and non

- road engines were part of the MANE

- VU SIP Modeling Inventory , prepared in 2002, as described on page s 29

- 34 of the proposed RH SI P revision. In the Ver sion 3 MANE

- VU SI P Modeling Inventory , the non

- road inventory was completely

redone because of changes that the EPA made to the NONROAD2005 model. The Department is presently examining and evaluating practices at oil and gas sites due to the increase in oil and gas development in Pennsylvania, to ensure that oil and gas development and operation proceed in an environmentall y sound manner. When the MANE

- VU SI P modeling inventory was being prepared, much of the oil and gas drilling activities in Pennsylvania had not begun. The emissions from the recent increase in oil and gas drilling, therefore, were not occurring and not part of the 2002 baseline inventory . Currentl y, the Department does not have adequate information to compile an accurate inventory fo r oil and gas exploration and production operations in future years. In accordance with Section 135.4 (relating to report format) contained in 25 Pa. Code Chapter 135 (relating to reporting of sources), the Department intends to advise owners and operator s of oil and gas exploration and production operations in Pennsylvania by December 2010 that they must submit a source report for air contamination sources b y March 1 of each ye ar, and that the reports must contain sufficient information to enable the Department to complete its emissions inventory . The Department intends to examine the emissions projections at oil and gas sites at the time of Pennsylvania’s first periodic regional haze progress report to determine whether they are properly characterized in all future

- year modeling inventories. The Department requires permits for the operation of the ty pes of diesel and nonroad engines ty

pically located at oil and gas sites

. As explained on page 11246 of the proposed RH SIP revision in Section 10.5.2 ( Measur es to Mitigate the Impacts of Construction Activities ), Section 2 of both the General Plan Approval and/or General Operating Permit (BAQ

- GPA/GP 9) and the General Plan Approval and/or General Operating Permit (BAQ

- GPA/GP 11), states that nonroad and diesel engines must have the best available technology (B AT) installed and in operation so that the engine is in compliance with regulated emissions standards; these general permits are federall y enforceable. Both general permits require the permittee to mainta in accurate records of the amount of time the engine is in operation per month and the amount of fuel used. In addition, the proposed RH SI P revision has been modified to include this paragraph o n page 112 : “The Department also requires a General Plan Ap proval and/or General Operating Permit ( BAQ

- GPA/GP

– 5) for natural gas, coal bed methane or gob gas production or recovery f acilities

. This General Permit authorizes construction and/or operation of a natural gas, coal bed methane or gob gas production o r recovery facility

. This permit authorizes the construction of internal combustion engine(s); dehy drator(s) and associated equipment that meet the best available technology (BAT) required under 25 Pa. Code §§ 127.1 and 127.12(a)(5)

. Once authoriz ation t o use GP

– 5 is granted, construction of the natural gas, coal bed methane or gob gas production or recovery facility designated in the application may proceed .”

8. **Comment:** There are many references to Dolly Sods Wilderness Area, while there are few ref erences to Otter Creek Wilderness Area, both of which are Class I areas in West Virginia. One example of this is on page 19, first paragraph, which seems to incorrectly imply that Dolly Sods and Otter Creek are the same Wilderness area. In paragraph 2, o n the page 19, reference to Otter Creek Wilderness Area should be included, but it is missing. Another example of this is on page 60 (last paragraph), where Dolly Sods is mentioned, but Otter Creek is omitted. This is in contrast to sentences in same par agraph that state Great Gulf IMPROVE monitor is representative of Presidential Range/Dry River Wilderness and also that Moosehorn IMPROVE monitor is representative of Roosevelt Campobello International Park. A suggestion would be to say that Dolly Sods IM PROVE monitor is representative of Otter Creek. And on page 61, Table 10.2

- 1, add Otter Creek to Dolly Sods column. **DEP Response:** The Department has corrected the references, or lack thereof, to Otter Creek Wilderness Area in response to this comment. Specificall y, the Department has revised pages 19 and 76 to include the reference that the Dolly Sods I MPROVE monitor is representative of the Otter Creek Wilderness Area. The Department has also revised Table 10.2

- 1 (relating to p ercent of m odeled s ulfate d ue to e missions from l isted s tates ) on page 77 of the proposed RH SIP to include Otter Creek in the Dolly Sods column.