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In accordance with the Regional Haze Rule (40 CFR 51.308(i)(3)), the Pennsylvania 

Department of Environmental Protection (DEP) is making available the comments 

received by the Federal Land Managers on the draft proposed Regional Haze (RH) 

State Implementation Plan (SIP) revision, and the DEP’s responses to those comments. 

The following is a reproduction of a comment letter received by the Department from 

the United States Fish and Wildlife Service (FWS) and the National Park Service 

(NPS), with DEP‘s responses 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 Rule 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 draft 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 considered 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 

always, 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 SIP 

to address many 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.
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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 quality controls, MANE-VU-generated progress 

goals are dependent on successful adoption and implementation of these controls. We 

believe that the Commonwealth‘s contribution to the success of the “Ask” is critical to 

achieving success in the region. 

DEP Response: The Department intends to pursue the control strategies identified in 

the MANE-VU “Ask” in accordance with Pennsylvania law. Page 95 of the proposed 

RH SIP 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 visibility

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 anticipated controls, the permit status of the SO2 

controls, and the anticipated SO2 emissions reductions achieved by 2018.” 

Additionally, page 97 of the proposed RH SIP revision states the following: “Based on 

the controls proposed, constructed and under construction in Pennsylvania, 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 SIP 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 25th and ends on November 29th, 2010. Additionally, the Department has 

revised the proposed RH SIP to address the status of the regulation development that 

pertains to the source categories considered in the Mactec Report (Appendix O). 

(Please see page 83 of the proposed RH SIP). These examples clearly 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. 
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DEP Response: It is not the Department’s practice to commit to adopting measures 

that must go through the notice and comment process under the Pennsylvania Air 

Pollution Control Act (APCA). Furthermore, the 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 undergo 

consideration by the Independent Regulatory Review Commission (IRRC) as well as 

the standing committees of the General Assembly after EQB consideration. 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 discussion of the five factors in the Best 

Available Retrofit Technology (BART) analyses. 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 analysis led to results that have been 

accepted as BART by 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 improvement. Instead, the Department employed 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. Conversely, only low 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 specifically 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 

presently not realized, nor are there commitments with implementation plans specified 

to accomplish these controls in the SIP. Therefore, more information should 

supplement the document that fully describes the uncertainty and whether the 

Commonwealth or the Regional Planning Organization has any 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 permitted source are subject to the 

notice and comment provisions 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, it is not the Department’s practice to commit to adopting 
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measures that must go through a public comment process. The 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 

undergo consideration by the IRRC 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 CAIR 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 I area located outside Pennsylvania 

that may be affected by 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 I areas 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 I areas that PA influences for the 20% worst and 20% best days. These data are 

available at the VIEWS website (http://views.cira.colostate.edu/web/). It is 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 requirement to commit to future monitoring.

DEP Response: Pages 23-24 of the proposed RH SIP revision include summary tables 

that display the IMPROVE data that shows baseline visibility for the 20% worst and the 

20% best visibility days based on the five-year average for 2000-2004, natural 

background visibility for the 20% worst and the 20% best visibility days, and the 

difference between baseline and natural visibility conditions for each MANE-VU Class 

I area and for nearby Class I areas. The Department considers 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 was 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 SIP revision for the public 

comment period. Section 6.4 describes additional monitoring information 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 Pennsylvania, a monitoring plan is not required under 40 CFR § 

51.308(d)(4).
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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: 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 analysis resulting in significant visibility improvement 

from controls would consequently justify higher cost controls. The Department 

maintains that a low $/ton control cost should not supersede an excessively high cost of 

visibility improvement. The Department does not believe that requiring additional 

controls on a BART 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 MANE-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 because it includes several 

control assumptions that are not reasonably OTW to implementation in the MANE-VU, 

MWRPO (Midwest Regional Planning Organization), and VISTAS states. Most 

problematic is MANE-VU’s choice to unilaterally increase Electric Generating Unit 

(EGU) emissions in MRPO and VISTAS 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 SO2 from non-EGU sectors though low 

sulfur fuel requirements by 2018 and that MWRPO and VISTAS States will reduce 

SO2 from their non-EGU sectors by 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 reasonable progress goals was helpful. PA should 

discuss how uncertainty in the federal CAIR program could affect the reasonable 

progress goals for the affected Class I areas. Please clarify whether PA’s CAIR rule 

requires specific SO2 and NOx reductions independent 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 accounted for emission controls already 

in place and emission controls that are not yet finalized but likely to achieve additional 
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reductions by 2018 in the “Ask” (beyond on the way) emissions modeling inventory for 

2018. The Department relied on technical analyses, including the modeling scenario, 

developed by 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 I areas affected by Pennsylvania’s emissions. The 

Department believes these modeled results are reasonable to achieve the reasonable 

progress goals in Class I areas affected by Pennsylvania’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 meet the sulfur content emission limits listed 

above by 2018. Please see the modifications to page 120 in the proposed RH SIP 

revision for the updated status of this low sulfur fuel oil regulation. CAIR has been 

remanded, but not vacated and remains in place until replaced. Pennsylvania’s CAIR 

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 mid2012. 

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 SIP 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. 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 meet the sulfur content emission limits listed above by 2018. Consideration of 

the regulation is anticipated to proceed on a schedule in accordance with the 

Pennsylvania Regulatory Review Act, the Pennsylvania Air Pollution Control Act, the 

Commonwealth Documents Law, the Commonwealth Attorneys’ Act and the 

procedures established by the Commonwealth’s Environmental Quality Board and by

the Department. The proposed RH SIP revision 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 would 
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reduce 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 by weight for No. 5, 6 

and heavier commercial fuel oils beginning May 1, 2012.” This statement will be 

updated at the time of final SIP submittal to account for further progress.

Regarding residential wood smoke, the proposed RH SIP revision has been modified on

page 83 to include the following: “New indoor wood stoves in Pennsylvania are 

regulated by 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 area sources (see page 106 of this SIP revision). A final-form 

outdoor wood boiler (OWB) regulation was approved by the Commonwealth’s 

Independent Regulatory Review Commission (IRRC) 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, for all new OWBs in the 

Commonwealth manufactured after June 1, 2011.” This statement will be updated at 

the time of final SIP submittal to indicate publication date of the OWB regulation as a 

final regulation.
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Attachment 1

To FWS/NPS Comments – Pennsylvania 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 analyses in making its BART determinations. 

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 

analysis led to results that have been accepted as BART by 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 PA DEP.

DEP Response: 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 analysis 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 I area as 

well as the cumulative benefits of improving visibility across all of the Class I areas 

affected.

There are several Class I areas impacted by Pennsylvania’s BART sources. We believe 

that it is appropriate to consider both the degree of visibility improvement in a given 

Class I area as well as the cumulative effects of improving visibility across all of the 

Class I areas 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 multiple Class I areas. Also, evaluating impacts at one 

Class I area, while ignoring others that are similarly significantly impaired, should not 

be done. Emissions savings from a source are benefits that will be spread well beyond 

only the most-impacted Class I area, 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 has 
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not explained how it incorporated this information about impacts upon all Class I areas 

into its BART decision.

For example, Wyoming evaluated cumulative visibility improvement for both its 

BART and reasonable progress determinations—following are excerpts from those 

Wyoming determinations (with emphasis added):

• Visibility impacts were addressed in a comprehensive visibility analysis covering all

three visibility impairing pollutants and associated control options. The cumulative 3-

year averaged visibility improvement from the baseline summed across the three 

ClassI areas achieved with LNB 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

• Visibility impacts were addressed in a comprehensive visibility analysis covering all 

three visibility impairing pollutants and associated control options. The cumulative 3-

year averaged 98th percentile visibility improvement from the baseline summed across

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 analysis 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 analysis covering all

three visibility impairing pollutants and associated control options. The cumulative 3-

year averaged 98th percentile visibility improvement from the baseline 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 visibility analysis covering all

three visibility impairing pollutants and associated control options. The cumulative 3-

year averaged 98th percentile visibility improvement from the baseline summed across

both Class I areas achieved with LNB with advanced OFA, upgrading 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 Results (percent improvement) 
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Total visibility impacts (sum of 98th percentile for all Class I areas)

The BART guidelines recommend analyzing 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 for 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 Department does not believe that 

adding additional parameters, such as total deciview days, would result in any other 

conclusions and would probably just add confusion to the analysis (e.g., more days 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 has provided no guidance on this issue of assessing visibility benefits that 

would result in multiple Class I areas when emissions are reduced from a given BART 

source, we commend Wyoming and Oregon for their initiative in addressing the issue. 

We also recognize that there is no “perfect” method for addressing cumulative benefits, 

but we firmly believe that Pennsylvania must show how it considered the cumulative 

impact of the BART sources the affected Class I areas. We have suggested an 

approach to Pennsylvania that is consistent with available information and with the

approach used by Wyoming and Oregon, and again request that Pennsylvania show 

how it has considered the cumulative benefits of potential BART reductions.

DEP Response: The EPA’s Guidelines for BART Determinations, Final Rule (40 CFR 

Part 51, July 6, 2005) does not stipulate a requirement for a “cumulative” impact 

analysis from one BART source on multiple Class I areas. 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 Class I areas when emissions are reduced 

from a given BART source, the Department maintains that such an analysis is 

unwarranted. 

The Department also maintains that requiring additional controls on a BART source to 

provide very small visibility improvements at multiple Class I areas due to an apparent 

low $/deciview visibility improvement cost is nether justified or appropriate. The 

summation of very small delta deciviews serves the mathematical purpose of increasing 

the delta deciview value with respect to the $/delta deciview equation and thereby 
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lowering the apparent cost of controls per delta deciview, while not providing any 

significant visibility improvement to any 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 Wyoming and 

Oregon BART sources. 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 analyzing 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. The Department applied 

the guidelines for the determination of BART for the affected sources. 

12. Comment: Based upon our reviews of BART analyses across the U.S., we believe 

that cost-per-deciview ($/dv) of visibility improvement is the most-common and mostuseful parameter for assessing the cost-effectiveness of strategies to improve visibility

in Class I areas. Our compilation7 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 that the cost per-deciview of visibility

improvement is the most-common and most-useful parameter for assessing the costeffectiveness of strategies to improve visibility in Class I areas, because the Regional 

Haze program was designed to improve visibility in Class I areas, 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 factors, and determined that a 

BART source analysis resulting in significant visibility improvement from controls 

would consequently justify higher cost controls. It should also be noted that the 

$/deciview cost in the example provided in the comment is an incremental 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-Catalytic Reduction (SNCR), or any additional controls, for all 

of its BART cement kilns.) We are also 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 than those from kilns in 

Pennsylvania. The total maximum 24-hour visibility impacts, 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-hour 
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visibility impact due to NO3 (nitrates) range from 0.03dv to 0.39dv. Therefore it was 

appropriate to require SNCR control systems as BART for the cement kilns in other 

states.
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14. Comment: AK Steel Corporation, Butler Works

BART 5 Factor Analysis:

STEP – 1: Identify 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: PA DEP should have included SCR in its analysis 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 

emissions, the following are the visibility impacts on the Class 1 areas:

Class I area Visibility Impact 

due to all sources

Visibility Impact 

due to EAF

Visibility Impact 

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 recently installed ULNB on two process 

furnaces. For the six processes that could utilize similar ULNBs 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 year as per the AK Steel submittal. AK Steel arrived at the 65% 

reduction factor by 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 provided 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 analysis that AK Steel provided. When 

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 any 
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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 technically feasible, but it is 

not economically feasible. It is the Department's experience that SCR will typically 

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 analysis resulting in significant 

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 considerably 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 (for 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 explain these estimates.

DEP Response: In its May 4, 2009, “Review Memo for BART Application for the 

Allegheny Ludlum Corporation Brackenridge Facility”, the Allegheny County Health 

Department (ACHD) conducted an engineering analysis under the BART determination 

process of 40 CFR 51.308(e) for each source subject to BART at Allegheny 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 Pennsylvania, the AK Steel Corporation, Butler Works, which recently

installed ULNB 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 analysis 

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 

Combustion. ACHD used the 65% reduction effectiveness figure to be consistent with 

the PA DEP use of that value in its AK Steel BART analysis. 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 ULNB s is figured at 65% reduction factor, resulting in emissions 

reductions of 14.2 tpy. 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 

analysis resulting in significant visibility improvement from controls would 
15

consequently justify higher cost controls. The maximum modeled deciview impact 

due to this BART source on the most impacted Class I area is considerably less than 0.5 

dv, the threshold suggested in the BART Guidelines to determine if a source 

contributes to visibility impairment.

16. Comment: Appleton Papers Inc. /Spring Mill

BART 5 Factor Analysis:

STEP – 1: Identify All Available Retrofit Control Technologies

NPS: PA DEP is incorrect in omitting Flue Gas Recirculation as a NOX 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 boiler, 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 commensurate visibility improvement.

Power Boiler #3 (SO2) Cost Effectiveness ($/ton) Cost of Visibility Improvement 

($/dv) $3,487/ton $51,200,000/dv

NPS: PA DEP should better explain these estimates.

STEP – 5: Evaluate Visibility Impacts

PA DEP: The total deciview 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 system 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 system. The resulting average 

cost effectiveness for installing the SDA system 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 DEP 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-linearity 

of CALPUFF 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 submittal 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 

significantly lower than 100% depicted here. Appleton's power boiler burns a 
16

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 only coal. The No. 4 

boiler is a 280 MMBtu/hr boiler where wet FGD is typically used. The Appleton boiler 

is 180 MMBtu/hr where wet FGD is typically not used. The required BART efficiency

on the Georgia Pacific boiler FGD is 90% which may be achieved by dry FGD as 

Appleton proposed for this evaluation. The Department concurs that FGR may be a 

technically feasible control option for a stoker boiler. However, the Department 

expects that a NOx cost analysis divided by some fraction of the total 0.057 deciview 

effect will yield similar results as the SOx calculations shown here. The Appleton 

boiler already 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 achieved.

The BART determination is consistent with the BART Guidelines. The Department 

considered all of the BART Guideline factors, and determined that a BART source 

analysis resulting in significant 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 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 Infeasible Options.

PA DEP: For Selective Non-Catalytic Reduction (SNCR), ammonia or urea would be 

injected into the rotating kiln at a location where the gas is within the temperature 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 systems.

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 system on one of its Midlothian, Texas, kilns 

and, according to Ash Grove, “is achieving a 35% - 40% NOX reduction on a consistent 

basis.”11

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies.

PA DEP: Removal efficiencies of the technically feasible NOx control technologies 

range from 18% to 35%.

NPS: PA DEP is incorrect. Both Colorado and Washington have proposed 40% NOx 

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 Impacts.

PA DEP: The maximum visibility improvement due to the most effective NOx control 

in the most affected Class I area (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 

analysis. 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 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.

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 analyses 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 Lyons,

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 shortcomings, the $1,014 per ton is lower than the $4,200/ton cost at Lefarge (WA) and the 

$7.5 million per deciview cost is below the national average of $13 million/dv for NOX 

BART.

DEP Response: The Department has recently finalized a statewide amended 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 Essroc’s NOx emissions from kiln #4 will be reduced 

approximately 20% by 2013 as a result of the amended Portland 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 

analysis resulting in significant 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 less than 0.5 dv, the 

threshold suggested in the BART Guidelines to determine if a source contributes to 

visibility impairment.
18

18. Comment: Lehigh Cement/York Operations

Step 1 – Identify All Available Retrofit Control Technologies.

PA DEP: Table 3 lists all available control technologies on the Lehigh\York White 

Cement Kiln for control of SO2 and NOx. Lehigh Cement conducted ambient modeling 

and visibility analysis for the period 2001 through 2003 at Class 1 areas affected by this 

facility. Visibility improvement is based on the company analysis.

NPS: PA DEP’s Table 3 is incomplete and does not include all of the eight NOX 

control technologies identified by Lehigh in its January 2006 BART analysis. We are 

especially 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 Infeasible Options.

PA DEP: SNCR has not been used full time on long wet or long dry kiln systems.

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 system on one of its Midlothian, Texas, kilns 

and, according to Ash Grove, “is achieving a 35% - 40% NOX 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 analyses 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 system is $ 

2,623 per ton of NOx removed and also determined to be Economically Infeasible. The 

estimated cost of a Cadence fan system is $ 1,118 per ton of NOx removed.

NPS: PA DEP failed to evaluate addition of SNCR without the Cadence fan system.

Conclusion:

PA DEP: The estimated 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 Impacts.

PA DEP: The maximum visibility improvement due to the most effective NOx control 

in the most affected Class I area (Shenandoah National Park) was 0.017 dv. The 

minimum cost of improvement was $ 10,606,000 annually per deciview, for lesser 

improvement. Therefore, I do not recommend any additional control of NOx as a result 

of the BART analysis. The current operating permit 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 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 analyses 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 Lyons,

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 

million/dv for NOX BART.

DEP Response: The Department has recently 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 Lehigh Cement/York’s NOx emissions from their white 

cement kiln will be reduced approximately 30% by 2013 as a result of the amended 

Portland 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 

analysis resulting in significant 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 less than 0.5 dv, the 

threshold suggested in the BART Guidelines to determine if a source contributes to 

visibility impairment.

19. Comment: 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 analysis, P.H. Glatfelter provided two revisions to their cost data and the basis 
20

of their cost calculations. Their most current cost analysis breakdown for the wet 

scrubber is in Table 4 of the third version of their cost analysis.

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 SO2 from Power Boiler #1. The overestimation 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 rate 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 by 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 SO2 

removed. Our application of the Cost Manual (see electronic attachment) yielded a 

TAC = $3.6 million and cost-effectiveness = $1,127/ton of SO2 removed.

STEP – 5: Evaluate Visibility Impacts

PA DEP: The 98th percentile deciview improvement expected by the installation of a 

wet scrubber system 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 98th percentile deciview improvement 

expected by operating the Number One Power Boiler existing OEC year 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 I areas 

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 Wilderness Areas which had visibility impacts about half of those at 

Shenandoah and Brigantine.) The cumulative benefits of reducing SO2 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 system for SO2 control on 

Number 1 Power Boiler, taking into account visibility improvement, was 

$24,545,196/dv. The cost effectiveness of operating the OEC system year-round for 

NOx 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 Manual 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 costeffectiveness for all of the SO2 controls we have seen proposed as BART nationwide. 

When one considers the cumulative benefits of improving visibility at the four Class I 

areas modeled by PA DEP, the cost-effectiveness drops below $9 million/dv, which is 

less than half of the $20 million/dv average cost-effectiveness for all of the SO2 

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 calculation 

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 

Power Plant

2 DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION BART Application 

Analysis AP-6041 May 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 Power 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 

Power 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 Power 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 CONTROLTECHNIQUES DOCUMENT -- NOX EMISSIONS 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 NOX emissions from a gas-fired, radiant tube, continuous annealing furnace at a 

steel mini-mill in the United States. This furnace also has LNB's. Controlled emissions from this unit are 

about 33 ppm at 3 percent O2. A second SCR unit, currently under construction, will be used to control 

NOX 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 power 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 two 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 western 

coals) and petroleum coke. After reviewing these potential options, the

NOx 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 followed 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 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 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 was one of the first

wet process cement plants in the world 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 Comments on Best Available Retrofit Technology (Section 8)

General Comments

20. Comment: No draft BART determination performed by the Pennsylvania 

Department of Environmental Protection (PADEP) resulted in a recommendation that 

BART controls be implemented on any 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 employed 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. Conversely, 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 –Evansville 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 ULNB

It is interesting that in Pennsylvania (PA), NOx controls on cement plants came out high 

in the BART cost rankings. Nationwide, many cement plants are controlling NOx from 

their kilns in their BART determinations, so in this sense if PA were to control NOx 

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 relatively 

expensive, even though the cost per ton of NOx or SO2 controlled was, in our opinion, 

very reasonable. In judging cost-effectiveness of a given control technology as defined 

under the EPA BART Guidelines1 in Step 4 (cost per ton of NOx, SO2 or particulate 

matter) and Step 5 (cost per deciview improvement), it is the position of the Federal 
25

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 analysis 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.

21. Comment: It’s important to note that two facilities in PA (Lehigh 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 by a 

facility. In this particular case the additive cost per deciview improvement could bring 

a control technology within 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 stipulate a requirement for a “cumulative” impact 

analysis from one BART source on multiple Class I areas. 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 Class I areas when emissions are reduced 

from a given BART source, the Department maintains that such an analysis is 

unwarranted. 

The Department also maintains that requiring additional controls on a BART source to 

provide very small visibility improvements at multiple Class I areas due to an apparent 

low $/deciview visibility improvement cost is nether justified or appropriate. The 

summation of insignificant delta deciviews serves the mathematical purpose of 

increasing the delta deciview value with respect to the $/delta deciview equation and 

thereby 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 analyzing 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. 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 company BART determinations should also be in the record. Please make 

these available in an Appendix.

DEP Response: The Department is making the original company BART submittals 

available to the public upon request during the public comment period.

23. Comment: Please provide a discussion of how the five factors were used in 

making the BART determinations. Since there are so many sources, a summary based 

on source category may be sufficient with detailed information that could be included 

as an appendix.

DEP Response: Summaries of BART determinations by source categories do not

convey the technical and detailed analyses the Department performed to make the 

BART determinations for each individual BART unit. The BART analysis review 

memos convey all the information the Department relied on to make its determinations

of BART, including how the five factors were used in making the BART 

determinations. The Department’s review memos are included in Appendix J (relating 

to Pennsylvania’s BART analysis review memos) of the proposed Regional Haze (RH) 

State Implementation Plan (SIP) 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 existing 

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 SIP revision on page 58

(relating to BART determinations, control levels and schedules) by 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 SIP 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 Wilderness Class I area 

(using the MM5 modeling platform) by this refinery is the largest visibility impact of 

any facility 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 Catalytic Reduction (SCR) on the 
27

Fluidized Catalytic 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 NOx 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 NOx 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 ULNB. The annual cost will remain at $316,919 / 

year. Sunoco conducted modeling that predicted an approximate 0.035 delta deciview 

improvement from the installation of ULNB, 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 analysis at this facility for BART is not 

warranted at this time.

26. Comment: United Refining Company

In comparing the Review 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 NOx control via Ultra Low NOx Burners at the Crude 

Heater are $3,266 per ton (PADEP 6/11/08 analysis). 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 Petroleum Refineries in the MidAtlantic Region (January 2007). The reason for such a discrepancy should be 

explained.

The Flue Gas Recirculation (FGR) alternative at $2,200 per ton of NOx 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 employed 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. The 
28

BART determination is consistent with the BART Guidelines. The Department 

considered all of the BART Guideline factors, and determined that a BART source 

analysis resulting in significant 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 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 NOx burners on Heaters 2H-3 and 2H-5 seem reasonable on a cost per ton 

basis ($1,775 and 2,148, respectively) and the cost per deciview ($7.0MM and 

$8.5MM, respectively) is not considered as excessive. These controls should be 

implemented as BART.

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 that 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 year of NOx reductions from a 2001-2002 baseline 

from boilers and heaters at the facility through the installation of controls or shut 

downs. The BART determination is consistent with the BART Guidelines. The 

Department considered all of the BART Guideline factors, and determined that a 

BART source analysis resulting in significant 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 considerably 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 on pages 3 and 8 to 

setting a NOx emission limit for the FCCU by May 2009. Since this date is past, the 

actual emission limitshould be inserted or another date should be set.

DEP Response: The Department agrees with the commentator. The BART table on 

page 58 and the discussion regarding consent decrees on page 103 in the proposed RH 

SIP revision have been modified to correctly describe the proposed final NOx limits for 

the FCCU from the enhanced SNCR installed in 2006. EPA proposed final NOx limits 

for 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 federally enforceable permit 
29

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 Units

Pursuant to earlier comments by the Federal Land Managers, PADEP performed an 

additional BART analysis on behalf of most of the Electric Generating Units (EGU). 

This additional BART analysis considered an Electrostatic Precipitator enhancement 

alternative, along with an objective visibility improvement analysis of cost per 

deciview, rather than relying on the subjective argument of “imperceptibility to the 

human eye” of any visibility improvement. The PADEP analysis lacked backup 

data/information and references for arriving at the conclusions, but it could be argued 

that relatively 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 Cheswick 

Plant) generally 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 conclusions. 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 agrees 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 determinations, control levels and schedules)

on page 57 of the proposed RH SIP 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 NOx and SO2 is complying with requirements of the Clean Air Interstate Rule 

(CAIR). An assertion is made on page 1-1 that CAIR will also reduce emissions of 

sulfates/inorganic condensable PM10 emissions. CAIR does not regulate sulfates and no 

further reductions will occur at this plant anyway.

DEP Response: While the Department concurs that CAIR does not directly regulate 

sulfates, the SO2 reductions due to CAIR 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 equipment, which is an 

electrostatic precipitator (ESP) and an under-construction Flue-gas desulfurization 
30

(FGD) system. BART for NOx and SO2 is CAIR. We commend Allegheny 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 analysis 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 figure. 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 overall visibility improvement 

warrants further consideration.

DEP Response: The Department 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 maximum 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 existing #6 Fuel Oils. BART for 

NOx and SO2 is CAIR. Low annual capacity factors of units (21% & 15%, respectively) 

result in large control costs on a per ton basis when examining ESP and venturi 

scrubber technology. PADEP should develop emission limits commensurate 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 Company

made an argument for 80%. Nevertheless, it would not change the final conclusion that 

controls would be too expensive for the benefit. Neither the PPL Generation BART 

determination nor the PADEP BART determination indicates that the facility is closed.

However, PADEP indicated on the FLM BART consultation conference call that the 

facility 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 during the BART conference call 

the information that the coal fired boilers at Martin's Creek, Units 1 & 2, are 

permanently shut down. The oil fired boilers, Units 3 & 4, are still in operation and are 

operated at the limited capacities as noted.

33. Comment: Orion Power – Cheswick Plant

The PADEP Review Memo did not consider an upgrade to the existing ESP, but 

considered only the cost of a new baghouse. The EPA BART Guidelines1 state that, “. . 

. you should consider ways to improve the performance of existing control devices, 

particularly when a control device is not achieving the level of control that other similar 
31

sources are achieving in practice with the same device. For example, you 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 deciview impact due to particulate matter at any one Class 1 area 

would not be cost-effective. 

34. Comment: Allegheny Energy – Mitchell Power Station

The reviewers did not locate a Company BART determination in the record. The 

PADEP Review Memo addressed the excessive cost of an ESP upgrade alternative.

DEP Response: 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 

Allegheny 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 – Eddystone 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 year 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 98th percentile basis. If only one year of 

meteorological data was used, visibility impact costs should be based on the maximum 

24-hour impact, rather than the 98th 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 corrected.

DEP Response: The Department concurs that the facility did use one year'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 NOx or SO2 

control.

A Selective Non-Catalytic Reduction (SNCR) system for the combined NOx emissions 

from long dry preheater Kilns #1 and #2 should be given more consideration as being 

cost-effective. Certainly, the $627 per ton of NOx removal is reasonable. The 
32

$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 by some other BART determinations that have been 

made. Our most extensive information about the visibility costs of NOx control for 

BART come from electric generation units. There are many instances of companyproposed BART NOx controls costing between $12 million and $35 million per

deciview for visibility improvement at a single Class I area. 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 NOx 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 any 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 of visibility improvement in a given Class I area as well as the 

cumulative effects of improving visibility across all of the Class I areas affected. It 

simply does not make sense to use the same metric 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 multiple Class I areas. And, it does not make sense to evaluate 

impacts at one Class I area, while ignoring others that are similarly significantly

impaired. In this case, the 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 98th Percentile deciviews) 

of SNCR deployment was shown as follows:

Shenandoah Brigantine

Kiln #1 0.02 0.04

Kiln #2 0.02 0.04

The result is a cumulative 98th Percentile deciview impact due to the deployment of a 

common SNCR on both 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 recently 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 Lehigh Cement/Evansville’s NOx emissions from kilns 

#1 and #2 will be reduced approximately 40% by 2013 as a result of the amended 

Portland cement kiln regulation. 
33

37. Comment: Lafarge Corporation/Whitehall Plant

PADEP’s conclusion 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 NOx or SO2 control.

A Selective Non-Catalytic Reduction (SNCR) system for NOx emissions from the dry

preheater Kiln #2 should be given more consideration as being cost-effective. A cost of 

$1,804 per ton of NOx 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 deployed as BART, regardless of the cost per deciview.

DEP Response: The Department has recently 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 does not believe that requiring additional controls 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 Lafarge’s NOx emissions from kiln-3 will be reduced 

approximately 25% by 2013 as a result of the amended Portland 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 

analysis resulting in significant 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 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% 

NOx control and an as-yet undetermined technology for a 10% reduction in SO2. The 

Company admitted that this is not a “typical” BART analysis and that CALPUFF 

modeling was not performed. In the absence of a full-company BART determination, 

PADEP performed a BART determination. PADEP concluded that SNCR at $1,014/ton 

NOx reduction and $4,678,401 per deciview of visibility improvement is too expensive 

and no additional control of NOx is warranted. The conclusion is incorrect. Both the 

$/ton and $/deciview are within an acceptable range for BART and should not be 

dismissed – especially in the absence of any state-defined guideline as to what cost 

ranges are considered acceptable for BART, per our discussion in the General 

Comments Section above. In addition, it seems that at a minimum, PADEP should
34

accept the company’s BART offer to install the water injection technology for a 7% 

NOx reduction and an “as yet” determined 10% SO2 control strategy, rather than 

concluding that no control technology is necessary.

DEP Response: The Department has recently 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 Cemex’s NOx emissions from each of their three kilns 

will be reduced approximately 20% by 2013 as a result of the amended Portland 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 

analysis resulting in significant 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 considerably less than 0.5 

dv, the threshold suggested in the BART Guidelines to determine if a source 

contributes to visibility impairment.

39. Comment: Keystone Cement Company – Bath Facility

It was stated in the Keystone 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 Keystone is constructing. However, PADEP listed 

proposed emission limits for Keystone 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 Keystone Kiln 2 should be zero.

The following discussion of SNCR for Keystone Kiln 2 may be moot if it is to be 

replaced by a new kiln before the five year BART deadline. A Selective Non-Catalytic 

Reduction (SNCR) system for NOx emissions from Kiln 2 should be given more 

consideration as being cost-effective. A cost of $1,014 per ton of NOx 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 deployed as BART, 

regardless of the cost per deciview.

DEP Response: The Department has recently finalized a statewide NOx control 

regulation for portland cement kilns which is viewable here: 

http://www.pacode.com/secure/data/025/chapter145/subchapCtoc.html
35

The Department does not believe that requiring additional controls 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 Keystone’s NOx emissions from kilns #1 will be reduced 

approximately 40% by 2013 as a result of the amended Portland 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 

analysis resulting in significant 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 less than 0.5 dv, the 

threshold suggested in the BART Guidelines to determine 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 Technology (RACT) benchmark 

limit of $1,500 per ton of NOx 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 Pennsylvania Regional Haze SIP which states, 

“The Department did not 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 

NOx control alternatives are well developed, but seem consistently higher than

commensurate values shown in EPA AirControlNET. Please discuss any 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 systems for SO2 control as 

a BART alternative because it was not demonstrated in practice. Actually, wet 

scrubbing is successfully deployed on oil-fired boilers being operated in Japan, Cyprus 

and Korea. This should provide reason enough to perform cost analysis 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 fuel for Boiler #26 and assuming 99% SO2 

reduction. A wet gas scrubber would not have impact benefits that exceeded these 

levels. The Department concludes 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 

analysis resulting in significant 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 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 Lime, Inc./Annville Operation Lime Kiln #5

PADEP proposed that no additional equipment be installed on Lime Kiln #5 for NOx 

control, even though both low NOx burners (LNB) and Selective Non-catalytic 

Reduction (SNCR) are technically feasible and cost-effective NOx 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 NOx control in long dry kilns. 

The most effective NOx control is SNCR at a cost of $1,014 per ton of NOx removed 

and $6,398,357 per deciview improvement at Dolly Sods Wilderness Area. LNB was 

shown to cost $1,318 per ton of NOx 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 Association2 noted that a relatively inexpensive, but effective 

NOx control technique, is a ‘high pressure air injection system’ (also called a mixing air 

system) that can be installed on the kiln. Mixing air systems have shown significant 

emissions reduction up to 48% on the 13 kilns operating with this technology. This 

should have been considered among the BART NOx control alternatives. 

The proposed NOx emission limit of 6.0 lb NOx/ton of lime should be reconsidered if a 

NOx 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 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 

analysis resulting in significant 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 considerably less than 0.5 

dv, the threshold suggested in the BART Guidelines to determine if a source 

contributes to visibility impairment.
37

42. Comment: United States Steel/Clairton Coke Works

Section 4 of the Review Memo stated that ACHD performed a BART analysis and the 

results are presented in that document. However, the record does not contain the 

detailed 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 by a referenced source (such as the OAQPS Control Cost Manual). In order 

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 analysis.”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 analysis under the BART determination process of 40 CFR 51.308(e) for 

each source subject to BART at the Clairton Coke Works. The review memo was 

submitted to the Department as part of its BART submittal for Pennsylvania. The 

details of the BART analysis consist of what was presented in Section 4 of the review 

memo, under the Subheading “BART 5 Factor Analysis,” and the following additional 

details are presented in this response to the comment:

For the USS Clairton Works facility, Step 1 of the analysis 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 burners. The 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/106scf, and Controlled –Low NOx burners = 140 280 LB/106scf, for a 

reduction factor of 50%. All of the boilers are larger than 100 MMBtu/hr and are preNSPS.

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 analysis 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. However, information is only

available for NOx post-combustion controls, and information related to NOx 
38

combustion controls, including low NOx burners, is identified as “planned.” Therefore, 

ACHD utilized 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 year. The NOx reduction from the 

installation of the ULNBs is now figured at 50% instead of the previous 65% reduction 

factor, resulting in emissions reductions of 145 tpy. 145 tpy, at $12,800 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 year. The NOx reduction from the 

installation of the ULNBs 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 Impacts” 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 Class 1 

area was found to be 0.0897dv. 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 previously 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 impairing 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, beyond the currently installed afterburner. Thus, no cost 

effectiveness calculations were performed for SOx from this unit. 

5. Conclusion: The conclusion is unchanged, even with the revised analysis. Based on 

the five-factor analysis, the impact of this facility does not warrant additional control. 

The Department concurred with the ACHD recommendation that compliance 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 determined that a BART source 
39

analysis resulting in significant 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 considerably less than 0.5 

dv, the threshold suggested in the BART Guidelines to determine if a source 

contributes to visibility impairment.

43. Comment: ISG Plate, LLC – Coatesville

Section 4 of the Review Memo stated that PADEP performed a BART analysis and the 

results are presented in that document. However, the record does not contain the 

detailed BART determination performed by the Department on behalf of the ISG 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 SO2 control was analyzed in Step 3 of the Review Memo, but in Step 5 

‘dry’ FGD is mentioned in the visibility analysis. This very possibly could be a 

typographical error. Wet FGD is capable of 98% removal, rather than the 90% 

assumed in the analysis, but again, even this change would not likely change the final 

conclusions.

In terms of cost per deciview improvement, please consider the effect on multiple Class 

I areas (i.e., Shenandoah National Park, Dolly Sods Wilderness Area and Otter Creek 

Wilderness Area), rather than just the Brigantine Wilderness Area, to determine the 

overall cost per deciview improvement.

DEP Response: The Department reviewed the NESCAUM CALPUFF data. As stated 

in the 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 feasible controls for NOx for EAFs. The Department does not 

concur that control of some portion of the remaining 0.033 deciview would be costeffective. 

The BART determination is consistent with the BART Guidelines. The Department 

considered all of the BART Guideline factors, and determined that a BART source 

analysis resulting in significant 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 considerably less than 0.5 

dv, the threshold suggested in the BART Guidelines to determine if a source 

contributes to visibility impairment.
40

44. Comment: Sunoco Chemicals – Frankford Plant

The cost analysis for NOx and SO2 control alternatives lacked detail in constructing the 

basis for Total Capital Investment. This information should be provided to allow a 

third party to check for reasonableness of the estimates. However, relatively minor 

adjustments to the NOx alternatives would not likely result in a change to the final 

conclusion that the alternatives are too expensive. In the case of wet FGD for SO2 

control, $2,836 is not an unreasonable cost per ton of SO2 removal, especially if a 98% 

control efficiency were used rather than the 90% figure assumed by the analysis. Again, 

if PADEP is willing to allow 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 worst 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 

analysis using a control efficiency 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 

analysis resulting in significant 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 considerably less than 0.5 dv, 

the threshold suggested in the BART Guidelines to determine if a source contributes to 

visibility impairment.

No comments were made on:

Dyno Nobel, Inc. Nitric Acid Plant

First Energy Generation Corp – Bruce Mansfield Plant

PPL Generation LLC – Montour

Exelon Power - Eddystone 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, Appendix Y. The U.S. Environmental Protection Agency finalized its BART 

Guidelines on June 15, 2005, and published the preamble and final rule text in the Federal Register on 

July 6, 2005. The rulemaking action added Appendix Y to Part 51, titled “Guidelines for BART 

Determinations Under the Regional Haze Rule.” See Section IV.D.Step 4.a.5.
41

In accordance with the Regional Haze Rule (40 CFR 51.308(i)(3)), the Pennsylvania 

Department of Environmental Protection (DEP) is making available the comments 

received by the Federal Land Managers on the draft proposed Regional Haze (RH) 

State Implementation Plan (SIP) revision, and the DEP’s responses to those comments. 

The following is a reproduction of a comment letter received by the Department from 

the United States Department 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 Ralph 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 appreciates the reviewer’s acknowledgment 

of the Department’s progress in developing the proposed Regional Haze (RH) 

State Implementation Plan (SIP). MANE-VU was formed by the Mid-Atlantic 

and Northeastern states, tribes, and federal agencies to coordinate regional 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 Regional Haze Rule (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 Pennsylvania efforts, the Department clearly 

and specifically indicates Pennsylvania’s efforts throughout the proposed RH 

SIP as they relate to the stated goals and emission management strategies and 

measures pursued by the MANE-VU regional planning organization to reduce 

the visibility impairment in the Class I areas of the Northeast and Mid-Atlantic. 

For example, page 95 of the proposed RH SIP 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 visibility 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
42

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, (including for reference purposes and where 

applicable, the BART facility identification number associated with the stack 

modeled in the MANE-VU Class I area 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 page 97 of the proposed RH SIP 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. 

Consistent with the MANE-VU ‘Ask’ Statement, the Department projects a 

94.5% reduction in SO2 emissions 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 SIP 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 Department’s proposed lowsulfur fuel oil regulation at its July 13, 2010, meeting. The public comment 

period began on September 25th and ends on November 29th, 2010. 

Additionally, the Department has revised the proposed RH SIP to address the 

status of the regulation development that pertains to the source categories 

considered in the Mactec Report (Appendix O). (Please see page 83 of the 

proposed RH SIP). 

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 facility 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 

stacks in Pennsylvania and controls identified from the MANE-VU 167 stack 

list) and 10.4.4-2 (relating to additional EGU stacks and controls in 

Pennsylvania) in the proposed RH SIP 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-VU 
43

CALPUFF modeling results for Pennsylvania BART sources), where 

applicable, for easy 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 controls, the permit status of the SO2 controls, 

and the anticipated SO2 emissions reductions to be achieved by 2018. Table 

10.4.4-2 provides similar information for several EGU stacks in Pennsylvania 

not identified on the MANE-VU 167 stack list that the Department 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 SIP in response to the comment to address the status of 

the regulation development that pertains to the source categories considered in 

the Mactec Report (Appendix O). (See page 83 of the proposed RH SIP). It is 

not the Department’s practice to commit to adopting measures that must go 

through a public comment process. 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 ensure 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 Pennsylvania’s 2002 emissions in tons 

per year) summarizes the Pennsylvania emissions, including emissions from 

stationary point sources, for 2002. Table 7.3.1-1 (relating to Pennsylvania’s 

2018 projected emissions) summarizes the projected emissions, including 

emissions from stationary point sources, in 2018 for Pennsylvania 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 year. These reductions are projections from all stationary point source 
44

sectors, and not solely from the CAIR-affected electric generating units (EGUs) 

in Pennsylvania. 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. Consistent with the MANE-VU ‘Ask’ Statement, the 

Department projects a 94.5% reduction in SO2 emissions from the EGUs 

identified from the MANE-VU 167 stack list, or from alternative measures, as 

appropriate and necessary, by 2018. The Department is relying on 

implementation of EPA’s CAIR replacement rule, the proposed Transport Rule,

for achieving the longer-term (2015-2018) SO2 reductions from the EGUs. The 

Department intends to re-evaluate the projections of SO2 reductions due to 

CAIR at the time of Pennsylvania’s first periodic report to determine whether 

the predicted reductions are realized. 

5. Comment: It would be helpful to include a summary of the non-EGU BART 

determinations as was in the previous draft.

DEP Response: The lengthy summaries of BART determinations by source 

categories contained in previous RH SIP drafts did not convey the technical and 

detailed analyses the Department performed to make the BART determinations 

for each individual BART unit. The BART analysis review memos convey all 

the information the Department relied on to make its determinations of BART, 

and the review memos are included in Appendix J (relating to Pennsylvania’s 

BART analysis review memos).

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 SIP revision 

demonstrate that the Department is pursuing the adoption 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 I areas. 

Shenandoah National Park in Virginia and the Dolly Sods/Otter Creek 

Wilderness Area in West Virginia are Class I areas in the Visibility

Improvement State and Tribal Association of the Southeast (VISTAS) region 

that are impacted by 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 Pennsylvania make additional reductions at emission sources 

located in Pennsylvania (see page 19 of the proposed SIP revision). 

The most recent modeling completed by VISTAS for the Class I areas in 

VISTAS showed the uniform rate of progress in 2018 would be met at both 
45

Shenandoah and Dolly Sods. VISTAS modeling results indicate that the 

projected level of emissions controls for Pennsylvania’s sources by 2018 will 

allow the Shenandoah National Park and Dolly Sods Class I area to meet the 

reasonable progress goals established by Virginia and West Virginia, 

respectively, by 2018. The emissions control strategy for the MANE-VU Class 

I areas’ reasonable progress analysis is, therefore, a reasonable emissions 

control strategy for the reasonable progress analysis for the Shenandoah 

National Park and Dolly Sods Class I areas. (Please see pages 64-66 of the 

proposed SIP 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 engines) 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 pages

29-34 of the proposed RH SIP revision. In the Version 3 MANE-VU SIP 

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 environmentally 

sound manner. When the MANE-VU SIP 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. Currently, the 

Department does not have adequate information to compile an accurate 

inventory for 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 operators of oil and gas exploration and production 

operations in Pennsylvania by December 2010 that they must submit a source 

report for air contamination sources by March 1 of each year, 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 types of diesel and 

nonroad engines typically located at oil and gas sites. As explained on page 112
46

of the proposed RH SIP revision in Section 10.5.2 (Measures 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 (BAT) 

installed and in operation so that the engine is in compliance with regulated 

emissions standards; these general permits are federally enforceable. Both 

general permits require the permittee to maintain 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 SIP revision has been modified to include this 

paragraph on page 112: “The Department also requires a General Plan 

Approval and/or General Operating Permit (BAQ-GPA/GP – 5) for natural gas, 

coal bed methane or gob gas production or recovery facilities. This General 

Permit authorizes construction and/or operation of a natural gas, coal bed 

methane or gob gas production or recovery facility. This permit authorizes the 

construction of internal combustion engine(s); dehydrator(s) and associated 

equipment that meet the best available technology (BAT) required under 25 Pa. 

Code §§ 127.1 and 127.12(a)(5). Once authorization to 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 references 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, on 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 paragraph 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 IMPROVE 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. Specifically, the 

Department has revised pages 19 and 76 to include the reference that the Dolly

Sods IMPROVE monitor is representative of the Otter Creek Wilderness Area. 

The Department has also revised Table 10.2-1 (relating to percent of modeled 

sulfate due to emissions from listed states) on page 77 of the proposed RH SIP 

to include Otter Creek in the Dolly Sods column.