Air Expertise Colorado , LLC

303.670.0515 mbarrett@airexpertisecolorado.com December 8 , 2015

Janet McCabe Acting Assistant Administrator
US EPA
District of Columbia

Shaun McGrath
Administrator
US EPA

- Region 8

Denver

Re: Martin Drake Plant Cause s Extensive and Severe Nonattainment Areas

- PM 2.5 , NO 2 and SO 2

Dear Admin i strators:

I am an air quality scientist and a licensed professional engineer that has been applying US EPA

recommended pollutant dispersion models to large electrical generating units, manufacturing and transportation sources for over two decades on behalf of municipalities, private industry, citizen
stakeholder , and environmental advocacy organizations. I have served as an air quality expert within p roceedings before state energy facility licensing boards

, 1 state and county courts and
commissions

, 2 air quality and environmental advisory boards

, 3 within litigation and air quality rulemaking proceedings

, 4 in Maryland, Massachusetts, Michigan, Virginia and Colorado

.

I report here on t he procedures and results of an ambient air quality analysis that evaluate s the impacts of pollutants from the Martin Drake Power Plant, with in public areas in Colorado Springs

, with respect to s hort

- term N ational Ambient Air Quality Standards (N AAQS ) for

PM 2.5 , NO 2 and SO 2 5

, 6

, 7 This analysis uses the recommendations of US EPA’s TAD (described herein) to calculate the historic al impacts of the Martin Drake p lant using the facility’s actual

1 Before Massachusetts Energy Facilities Siting Board, 2009, on behalf of Billerica Watchers.

2 Before Virginia State Court on behalf of City of Alexandria; before Harford County Peoples’ Court on behalf of River Hills Club; before county commissioners for Ludington, Manistee and Traverse City on behalf of West Bay Exploration and Omimex Energy ; 199 9

– 2001.

3 Before Virginia Air Pollution Control B oard on behalf of City of Alexandria, 2005

– 2008 and before Michigan Environmental Science Board on behalf of Michigan Oil and Gas Association; 1999.

4 As appointed member of PM 2.5 Implementation Board, Virginia Department of Environmental Quality, 2007

- 2008; before Maryland legislators for coal combustion flyash rulemaking on behalf of Environment Maryland; written testimony on behalf of Earth Justice in Colorado oil and gas rulemaking, 2014.

5 “ Nati onal Ambient Air Quality Standards for Fine Part iculate Matter; Final Rule,” 40 CFR Parts 50, 51 and 52, et. al. Fe deral Register, January 15, 2013, at http://www.gpo.gov/fdsys/pkg/FR

- 2013

- 01

- 15/pdf/2012

- 30946.pdf

. 6 “Primary National Ambient Air Quality Standard for Nitrogen Dioxide; Final Rule,” 40 CFR Parts 50 and 58, Federal Register, February 9, 2010, at http://www3.epa.gov/ttn/naaqs/stand ards/nox/fr/20100209.pdf

. 7 “ Primary National Ambient Air Quality Standard for Sulfur Dioxide; Final Rule, ” 40 CFR Parts 50, 53 and 58, Federal Register, June 22, 2010 , at http://www3.epa.gov/ttn/naaqs/standards/so2/fr/20100622.pdf

.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 2 of 18

303.670.0515 mbarrett@airexpertisecolorado.com emissions and operational timeline

– in essence, to create SO 2 impacts that monitors would see had they been in place at all locations to which the public has access around the plant.

Contrary to the belief that their inaction suggests city and state official s hold, 8 the NAAQS are not abstruse benchmarks stipulated in order to inhibit power production. Instead, as you know, NAAQS are derived by the judgement of health and medical experts based on their review of
studies and observations of health effects that occur in response to exposure to these air pollutants. NAAQS are approximately equivalent to the maximum levels of pollutants that can occur in ambient air, before health effects start to occur in exposed individuals, with a margin of safety included. NAAQS inc lude a margin of safety, i.e., t he level is made more stringent, to
address , as US EPA describes, the “uncertainties associated with inconclusive scientific and technical information available at the time of standard setting...” and to “provide a reasonable degree of protection against hazards that research has not yet identified.” 9

Using procedures recommended by US EPA

, I find that the impacts in public areas from the
Martin Drake Power Plant’s three stacks exceed th e NAAQS for SO 2 , NO 2 and PM 2.5 , in extended areas at egregious levels. These results occur even in the absence of consideration of impacts from all of the Martin Drake’s sources and from other regional and nearby sources

, including the significant contributions by the adjacent interst ate highway and its associated high
volumes of mobile sources.

Give n the severity a nd extent of these areas of nonattainment : a) at levels that likely o verwhelm
the margin of safety that each NAAQS include; b) that derive from methods that err on the side
of under estimation of actual impacts ; and c) in which multi

- pollutant exposure in exces s of the NAAQS o verlaps spatially and temporally, it is extremely likely and probable that citizens working and living around the Martin Drake have experienc ed for decades

, and continue to experience

, health effects from their chronic exposure to the Martin Drake p lant’s pollutants.

Background

-- Multiple Previous Air Quality Impact Analyses show Nonattainment

The Martin Drake is a 278 MW coal

- fire d electrical generating station in a highly urban ized area of Colorado Springs. Residential areas and high density commercial districts line the plant boundary to the southeast and northeast, respectively. The facility’s unfenced and uncovered coal pile a nd coal processing operations lie between the plant and the interstate highway to the

8 Modeled results s howing violation s of the NAAQS were reported within separate independent engineering analyses to City Council (a body that also acts as the Board of the Colorado Springs Utilities) starting in 2012, and within hearing comments and reports to City Council in 2013 and 2014

. 9 Integrated Science Assessment s (ISA) Legislative Requirements, at http://cfpub.epa.gov/ncea/risk/recordisplay.cfm?deid=202463&CFID=51886408&CFTOKEN=78300088

.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 3 of 18

303.670.0515 mbarrett@airexpertisecolorado.com west (I

- 25). This interstate highway also separates the plant from additional residential and light
industrial areas to the west.

Each of t hree boilers (Boilers 5, 6 and 7) emit s through a dedicated stack , with heights of 200
feet for Boilers 5 and 6 and 250 feet for Boiler 7. 10 T hese boilers were placed in s ervice 53, 47, and 41 years ago, respectively. Table 1 presents allowed boiler heat input ratings and permitted
emission limits , as presented within the facility’s expired Title V (operating) permit. 11 Although the operating permit which stipulates t hese emi ssion limits has been expired for over eight years, in contra vention of state regulations, no renewed permit limits have been issued f o r the plant. 12

A previous analysis of air quality by Air Expertise Colorado, LLC (AEC) used these maximum
allowable emission rates for SO 2 within an ambient air quality analysis (included with this
submittal as Attachment 1) . These results were presented in September, 2013 to state ( i.e., Air Pollution Control Division) and Ci ty of Colorado Springs’ officials. Results show widespread
areas of nonattainment of the SO 2 1

- hour NAAQS around the plant. 13 A ir quality compliance
demonstrations by a

nother licensed engineering firm, i.e., Wingra Engineering

, also show severe
and extended areas of nonattainment. 14 One of these st udies was presented to City of Colorado Springs and APCD officials in late 2012 and early 2013, respectively. W ingra Engineering’s most recent analysis, 15 which studied impacts using forthcoming changes at the plant, was presented to city and state officials in mid

- 2015. To summarize, all air quality analyses of the

Mart in Drake plant, including the analysis reported herein, all conducted by engineering professionals using US EPA guidelines and procedures

, show SO 2 nonattainment in Colorado Sprin gs for a full range of actual, potential and forthcoming emission scenarios

.

10 From Martin Drake Plant entries within ‘Stack Flue’ worksheet within “EnviroEquipY2012” spreadsheet; from
EIA860 database.

11 Colorado Department of Public Health and Environment, Operating Permit, Colorado Springs Utilities Martin Drake Power Plant, Operating Permit no. 95OPEP107, Expiration Date Oct. 30, 2007. Boilers 5, 6 and 7 were placed in service in 1962, 1968, and 1974, respectively.

12 Department of Public Health and Environment, Air Quality Control Commission, Regulation no. 3, Stationary Source Permitting and Air Pollution Emission Notice Requirements, Section II I.B.6 states that “[e]ach source subject to an operating permit shall submit an application for renewal of the operating permit at least twelve months, but not more than eighteen months, prior to expiration of the operating permit.”

13 Letter to Interim Dir ector Karin McGowan, September 2 3 , 2013.

14 “Martin Drake Power Plant

– Colorado Springs, Colorado

– Sierra Club Evaluation of Compliance with 1

- hour SO2 NAAQS, October 4, 2012, S. Klafka, P.E., Wingra Engineering, Madison. http://content.sierraclub.org/coal/sites/content.sierraclub.org.coal/files/Evalu ation%20of%20Compliance%20with% 20the%201

- hour%20NAAQS%20for%20SO2%20

- %20Martin%20Drake%20CO%20DRAFT,4oct12.pdf

. 15 “Martin Drake Power Plant, Colorado Springs, Colorado, Evaluation of Compliance with the 1

- hour NAAQS for SO2,” August 5, 2015, by S. Klafka, P.E., Wingra Engineering, S.C., Madison.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 4 of 18

303.670.0515 mbarrett@airexpertisecolorado.com Current Analysis

– Actua l Emissions and Operations Also Show Historical Nonattainment
of SO 2 NAAQS caused by Martin Drake

During the period of 2011 through 2013, the Martin Drake plant emitted 15,031 tons of SO 2 to
the ambient air of Colorado Springs. 16 Scientific evidence links short

- term exposures to SO 2 concentrations ( for duration exposures as short as 5 minutes ) with a range of adverse respiratory
effects

, including bronchoconstriction and increased a sthma symptoms. About one in every

twe lve adults, and one in every ten children in th e US are asthmatic, 17 and a sthmatics with
increased rates of ventilation (e.g., while exercising or playing) are particularly affected by exposure to SO 2 . Studies also show a connection between short

- term exposure to SO 2 concentrations and an increase in the number of visits to hospital emergency departments and hospita l admissions for respiratory illnesses, particularly among children, the elderly, and
asthmatics. 18

T hi s current analysis adds to the studies of the impacts of the Martin Drake plant, and follows guidelines released by US EP A in early 201 4 for analyses that assess nonattainment status for the
2010 1

- hour SO2 NAAQS

, 19 i.e., the “SO 2 NAAQS Designation Modeling Technical Assistance Document ( or TAD). Accordingly, this analysis uses AERMOD to simulate impacts using the plant’s actual timeline of emissions and operating characteristics, in order to reproduce and
assess how the actual historical impacts of SO 2 from the plant complied with the 1

- hour SO 2 NAAQS.

16 US EPA Air Markets data downloaded for Martin Drake; epa.gov/ampd.

17 http://www.aaaai.org/about

- the

- aaaai/newsroom/asthma

- statistics.aspx.

18 http://www3.epa.gov/airquality/sulfurdioxide/health.html.

19 “ Sulfur Dioxide (SO 2 ) National Ambient Air Quality Standards Designations Modelin g Technical Assistance Document , Draft, December 2013 ; r eleased in early 2014.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 5 of 18

303.670.0515 mbarrett@airexpertisecolorado.com Table 2 presents s tack characteristics for each boiler as reported by the US Energy Information
Administ ration

, 20 and s tack flow and temperatures for each of min inum , mid and maximum
load s that derive from results of Relative A ccuracy Test A udits (RATAs) at the plant in mid

201 3

. 21 In order to reproduce an emissions and operational timeline for the facility and each
boiler (i.e., hourly emission rates and stack velocity and temp er atures), US EPA Air Markets hourly data were accessed for SO 2 and NO x emission rates and heat in put rates for each boiler for years 2011 through 2013 (as derive d from in

- stack monitors ) . Best

- fit relationships for each of velocity and temperature as a functio n of load were formed using RATA observations ; hourly
load levels were then used with in these best

- fit relationships to calculate actual hourly velocities and temperatures for each boiler, for each hour of 2011 through 2013. These hourly records of emission rate, temperature and velocity were included within the file ’HOUREMIS’ within the AERMOD input run stream.

Meteorological data derive from National Weather Service observations at the Colorado Springs Municipal Airport, approximately six mile to east of the plant. These data include ASOS observations, a nd according ly the pre

- processor AERMINUTE was applied prior to AERMET.

Dimensions of downwash parameters for the Martin Drake were calculated using the BPIP

PRIME algorithms. Plant layout was determined using Google Earth images; boiler building heights derive from architectu ral drawings relayed by Colorado Springs Utilities

. 22 To iterate, a ll procedures used in this analysis conform to the US EPA’s TAD recommendations for these types of analyses, i ncluding:

20 2012 Form EIA

- 860 Data

- Schedule 6, 'Stack and Flue Data. ’

21 Airtech, Report on the Relative Accuracy Test Audits, Report Dates of July 1, 2013; June 28, 2013; and June 27, 2013 for Units 5, 6 and 7.

22 Files relayed on August 28, 2015 in response to Colorado Open Records request, by J. But ler of CSU, including “69

- 4

- AR

- 5.JPEG” showing boiler building elevations.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 6 of 18

303.670.0515 mbarrett@airexpertisecolorado.com - Application of the preprocessor AERSURFACE to determine albedo, surface roughness
and Bowen ratio around the meteorolo gical observation site;

- The urban option with associated current population assignment to reflect the urban and surface heating characteris tics around the power plant site;

- Terrain characterization determined by AERMAP using USGS National Elevation
Databas e information for the area.

Figure 1 shows contours of the 4 th highest daily 1

- hour maximum for the years 2011 through
2013. Shaded areas that exceed the NAAQS encompass approximately two to three square miles, in an area of the city where population density is high.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 7 of 18

303.670.0515 mbarrett@airexpertisecolorado.com State Respon ds to Engineering Reports of SO 2 Nonattainment by Placement of One
Monitor

– CSU Then Requests Assistance from Professional Meteorologists to Forecas t High Impact Conditions

Following the public release, in October , 2012 of the Wingra Engineering study showing severe and widespread nonattainment of the NAAQS in Colorado Springs from the Martin Drake’s SO 2 emissions, an SO 2 monitor was located by the Colorado Department of Public Health and Environment appro ximately one kilometer distant from the northwestern edge of the plant’s boundary . In response to the September, 2013 letter by AEC showing widespread exceedance of
the SO 2 ambient air quality standard using the facility’s permitted rates, Deputy Director
Kaufmann wr ote , in November, 2013, that :

“ as required by federal law, CDPHE has installed an SO 2 monitor in the area to directly measure ambient SO 2 concentrations....since the begin n ing of 2013, [t]herefore there is not the requisite three years [sic] worth of data necessary to evaluate whether the area is complying with the NAAQS ...the actual monitored values do not support the conclusion that the area is violating the SO 2 NAAQS. ”

Then, i n correspondence dated December 31, 2013, Colorado Springs Utilities’ air qual ity consultants (i.e., as e mployees of AECOM) wrote to Vicki Card, Environmental Services Supervisor of Colorado Springs Utilities, stating that :

“we understand that CSU would like to discuss the feasibility of identifying, in advance, meteorological condi tions that may lead to elevated ambient SO 2 concentrations. Operations during these predicted events would be altered to include switching one or more coal

- fired units to natural gas to address the compliance requirements. Generally, a weather forecasting and/or dispersion modeling predictive met hod has not been allowed for demonstrating compliance, but we will discuss any of your past discussions with CDPHE or US EPA regarding this approach.” 23

Indeed, d ispersion method techniques , in which meteorological conditions are predicte d and plant operati ons are changed to reduce impacts, are prohibited by the Clean Air Act. 24 The actions of APCD and CSU (which the statements of their consultant indicate may have been
coordinated ) exemplify why these dispersion techniques are prohibited: Deputy Director Kauffmann attempts to persuade that the single SO 2 monitor is sufficient to characterize the
attainment status of the entire Colorado Springs area, while Colorado Springs Utilities ask s for

23 B. Macdonald, Ph.D.; P. McKean, CCM; and S. Duncan of AECOM to V. Card, December 31, 2013. Included within files relayed to M. Barrett of AEC from CSU in response to Colorado Ope n Records Act request.
24 40 CFR 51.166 Prevention of Significant Deterioration, “...the degree of emission limitation required for control of any air pollutant under the plan shall not be affected in any manner by ...2) any other dispersion technique...”Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 8 of 18

303.670.0515 mbarrett@airexpertisecolorado.com guidance from their professional meteorological consultant on how to predict meteorological

co nditions that sh ow high impacts.

This shows an unabashed interest by this owner/operator and the agency in misleading the public away from a full and open accounting of the plant’s pote ntial worst case impacts

. What happens for the majority of the hours when the wind direction and conditions are forecast to send the plume toward the many quadrants and sectors around the pl ant where there is no monitor?

Such a potential for decei t and un limited ex ceedance of impacts is why a permit that protects against violations of health

- based standards for all potential weather pattern s and conditions and emissions is necessary. Accordingly, the Clean Air Act prescribes that NAAQS

- based emissions
li mits for major sources be set using dispersion models that calculate those protective limits for the widest possible range of all meteorological conditions and maximum potential emissions. The US EPA Guideline on Air Quality Models states that use of a r epresentative five

- year meteorological data set assures that the greatest potential range of actual conditions are incorporated in the analysis. 25 In essence, the results of a modeled approach assure against
violations of health

- based standards for the potential convergence of worst

- case events.

Current Analysis

- NO 2 Impacts by Martin Drake Also Show Nonattainment

US EPA reports that short

- term NO 2 exposures (ranging fro m 30 minutes to 24 hours) are linked to adverse respiratory effects including airway inflammation in healthy people and increased respiratory symptoms in people with asthma. Studies also show a connection between breathing
elevated short

- term NO 2 concentr ations, and increased visits to emergency departments and hospital admissions for respiratory issues like asthma.

NO 2 concentrations near roadways are appreciably higher than those measured at monitors in a regional network. These high concentrations of NO 2 are especially concerning for residents that live adjacent to roadways. 26

The Martin Drake plant is also a larg e source of NO x emissions (that convert to NO 2 in the ambient air). During the period of 2011 through 2013, th e M artin Drake plant emitted 11,477

tons of NO x to the ambient air of Colorado Springs. T he Martin Drake plant is currently undergoing the implementation of a pollution control project at each of B oilers 6 and 7 to reduce
SO 2 emissions, i.e., the Neumann S ystems Group technology, in accordance with the facility’s

25 “ US EPA Guideline on Air Quality Models,” Federal Register, November 9, 2005, page 68244 reports on a study that “indicated that the variability of model estimates due to the meteorological data input was adequately reduced if a 5

- year period of record of m eteorological input was used.” Referenced study is “Burton, C.S., T.E. Stoeckenius and J.P. Nordin, 1983. The Temporal Representativeness of Short

- Term Meteorological Data Sets: Implications for Air Quality Impact Assessments. Systems Applications, Inc., S an Rafael, CA. (Docket No. A

- 80

– 46, II

- G

– 11).

26 http://www3.epa.gov/airquality/nitrogenoxides/health.html.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 9 of 18

303.670.0515 mbarrett@airexpertisecolorado.com requirements to meet regional haze emission standards. 27 This pollution control project will
red uce flue gas temperatures, which in turn will lead to reduced plume buoyancy and higher ground

- based impacts for pollutants that are not being controlled. Accordingly, the pollutants
for which the SO 2 control project is expected to increase ground

- based impacts from the Martin Drake plant include NO 2 , PM 2.5 , CO and a wide variety of hazardous air pollutants. Although the contract for this project was entered into during the 2011 to 2012 t imeframe with the provider, long after after the 1

- hour 2010 SO 2 NAAQS was finalized, no analysis of the project’s ability to meet the 1

- hour 2010 SO 2 standard was requested of the provider by city officials. 28

The C lean Air Act allows the inclusion of dispersion techniques for pollutants for which a control project is contemporaneously implemented. For other non

- reduced pollutants, any credit for reduction in poll utant impacts from dispersion techniques such as flue gas reheat are not allowed within compliance demonstrations. Accordingly, for NO 2 and PM 2.5 for which no pollution control project is being implemented at the plant, this analysis uses the flue gas
temperature that the co oling by the Neumann Systems Group technology incurs

. While observations of these post

- Neumann Systems Group implementation stack temperatures are not yet available, industry reports of this type of control technology at coal

- fired boilers suggest that
fl ue gas temperatures may drop significantly , for example, to approximately 125 to 160 deg. F

. US EPA’s predictions show that because of flue gas temperature reductions, desulfurization projects at coal

- fired power plants can increase ground

- based impacts o f NO 2 by up to 160 %

over pre

- SO 2 control project implementation

. 29

This analysis uses an estimate for the reductio n in flue gas temperature (with a minim um of 201 deg. F) that very likely errs on the side of overestimating the stack gas temperature 30 and

27 Letter, Michael Brady, P.E., Technical Services Supervisor of Colorado Springs Utilities to Kirsten King, Stationary Sources Program Manager, Air P ollution Control Division, Colorado Department of Public Health and Environment, June 2, 2010. Emission limit required for Boilers no. 6 and 7 are stated to be 0.15 lb per MMBtu on a 30

- day rolling basis.

28 Multiple requests for an analysis to assess th e effect of the Neumann Systems Group technology on the capability of the Martin Drake to meet all NAAQS were made within public comments before Colorado Springs City Council/Utilities Board in 2013 and 2014.

29 A portion of the water in the slurry is e vaporated and the waste gas stream becomes saturated with water vapor. For example, at Pubic Service Company’s Cherokee station, installation of SO2 scrubbers reduced flue temperatures to approximately 160 degrees (from “Retrofitting Lime Spray Dryers at Public Service Company of Colorado,” R. Telesz; J. Doyle of Babcock and Wilcox Company and R. Larson of Utility Engineering, presented at POWER

- GEN International 2000, Orlando, November 14

- 16, 2000 ) . See also “Stack Gas Reheat Evaluation,” EPA

- 600, US EPA ’s Industrial Environmental Research Laboratory, Research Triangle Park, March, 1980, which presents predictions of maximum ground

- based impacts as a function of un

- scrubbed and scrubbed stack gases. See also US EPA’s Air Pollution Control Technology Fact Sheet, EPA

- 452/F

- 03

- 034, Flue Gas Desulfurization (FGD)

- Wet, Spray Dry, and Dry Scrubbers, at www.epa.gov/ttn/catc , in which the energy, i.e., heat, available for steam production is reduced.

30 This analysis assumes a post

- Neumann System Group temperature in the stack of 201 deg. F.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 10 of 18

303.670.0515 mbarrett@airexpertisecolorado.com therefore underestimates impacts of NO 2

. Usi ng this assumption, a historical timeline of NO x emissions was formed, using updated best fit relationships between temperature, velocity and
load. NO 2 impacts from the plant were predicted using the 2011

- 2013 hourly timeline of NO x emissions and boiler operating conditions, b ut reduced flue gas temperatures are used to reflect
the N eumann S ystem G roup project’s implementation.

Figure 2 shows these results ( assuming Tier 1 assumptions regarding NO x to NO 2 conversion )

. 31 Note that these results do not include background levels of NO 2 , nor do they include the
contribution to NO 2 impacts by the close

- by and heavil y

- travelled interstate. Annual average daily traffic volumes along this section of high way exceed 110,000 vehicles per day, and 6% to
8% of tho se volumes are trucks

. 32 These interstate sections also show v ery high volume

- to

capacity ratios, suggesting conditions of conge s tion , which were shown to lead to NO 2 and/or

PM 2.5 NAAQS exceedances on adjoining residential areas along another highly

- travelled
interstate

. 33 T

he very close distances associated between t he plant and interstate suggest that contributions by mobile sources will be significant in exactly those areas that are already heavi ly impacted

, at levels exceeding the NAAQS , from the plant’s NO 2 emissions.

31 Full conversion of NO
x to NO 2
. 32 Colorado DOT Online Transportation Information System ( http://dtdapps.coloradodot.info/otis ) for the sections of I25 adjacent to the Martin Drake Power Pla nt.
33 For ano ther high

- volume interstate, an AERMOD

- based analysis of air quality impacts showed that NO 2 and
PM 2.5 NAAQS were exceeded within adjacent residential communities. See “I

- 95 HOV/HOT LANES Northern Terminus: Air Quality Impacts on Adjacent and Nearby Communities in Fairfax County, Virginia,” submitted to J. Britton of Schnader

, Harrison Segal & Lewis, LLP, Washington, DC 20001 and Concerned Residents of Overlook LLC, Fairfax County, December, 2012 , by AEC. Also presented to Virginia Department of Transportation.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 11 of 18

303.670.0515 mbarrett@airexpertisecolorado.com Current Analysis

–

Martin Drake causes Nonattainment by its PM 2.5 Emissions

Coal

- fired power plants release significantly more particulate pollution than do other fossil

- fuel plants, and a large fraction of that particulate pollution is PM 2.5 . These tiny particles, too small to see, are inhal ed deep er into parts of the lungs that are more vulnerable to injury, potentially causing an array of health problems, including immune system suppression; cancer; and
cardiovascular disease. Population subgroups that are most at risk from exposure to PM 2.5 are

a ctive children; the elderly; and all who are active outdoors. 34

34 http://www3.epa.gov/pmdesignations /faq.htm

.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 12 of 18

303.670.0515 mbarrett@airexpertisecolorado.com For the period of 2011 through 2013, the Martin Drake plant emitted a pproximately 3,700 tons of particulate matter from its boiler stacks, a large fraction of that in the fine range 35 (this amount does not reflect any of the particulate matter emissions from the multiple other non

- boiler sources at the Martin Drake plant

– see below ). The impacts of PM 2.5 were calculated here using

t he Martin Drake plant ’s allowable emission rates for all three b oilers , emitted according to the hourly operational timeline for the years 2011 through 2013 (as also used in the SO 2 and NO x analyses)

. Note that multiple other PM 2.5 sources at the facility were not included in the analysis
to date . N umerous additional sources around the facility are expected to emit PM 2.5 and consequently to add to PM 2.5 impacts at offsite facilities. Additional contributions to PM 2.5 in

areas ar ound the plant that derive from the plant’s operation include:

- Fugitive emissions from coal

- loa ded railcars as they e nter the site and remain parked, with no covers;

- Fugitive emissions released as coal

- loaded r ailcars are dumped at coal transfer sites;

- Fugitive emissions produced by wind as it moves over the uncovered and uncontrolled coal yard;

- Fugitive emissions from material handling processes that move coal from the yard to the coal conveyor;

- Fugitive emis s i ons from the coal conveyor and coal pulverizer;

- Stack emissions released from vent points on the coal combustion by products (CCBs) silos;

- The fugitive emissions from loading CCBs f rom the silos to the trucks that bring CCB s to offsite locations;

- Fugitive roadway emissions from these CCB

- carrying and sorbent

- carrying t rucks along the site’s roadways;

- Fugitive emis sions from the unloading of s orbent

- carrying trucks into sorbent silos;

- Stack emissions releas ed from vent points on the sorbent

- storage silos ;

- High volume truck and other mobile source traffic on the close

- by interstate;

- Opacity exceedances t hat may ha ve resulted in emission rates of PM 2.5 from the plant’s stack that exceed the allowed emission limit by multiple times;

- Contributions to PM 2.5 from SO 2 and NO x emissions that combine to form particulate

matter in ambient air.

35 Using EPA Air Markets data for the years 2011 through 2013, for each boiler’s hourly heat input rate and the allowable PM emissions rate. Note that no quantitative continuous measure of PM 2.5 or PM 10 emissions is in place at the Martin Drake. Opacity excursions can lead to multiple times the allowed rate of PM emissions at coal

- fired power plants.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 13 of 18

303.670.0515 mbarrett@airexpertisecolorado.com Currently there are no continuous emissions monitors for PM in u se in the Martin Drake’s stacks, even though these instruments are used at many other coal

- fired power plants. 36 While opacity is a poor quantitative indicator of the amount of particulate in the flue gas stream , it is currently the only surrogate by which particulate emission rates can be continuously evaluated at the Martin
Drake

.

The Air Pollution Control Division allows e xceedances of opacity from the Martin Drake for

common operational situation s, including boiler startup and load changes. More specifically, t he
Martin Drake’s stacks’ maximum opacity level of 20% can increase up to 30% for a period or periods aggregating up to six minutes in any cons ecutive 60 minutes

, 37 during these specific operational conditions

, without violating its opacity requirements.

F or this plant, these o pacity exc ursions may translate into PM emissions that significantly exceed
the allowed PM rates. For example, observations of PM emissions as a function of opac ity at
another coal

- fired boiler show that an opacity level of 30% equates to an emission rate of 0.3 lb per MMBtu, which represents three times the allowed level for the Martin Drake stacks , and depending on the frequency of load changes and startup, may occur for approximately 10% of
boiler operation

. 38

Note that the results of Figure 3 depe nd on the unlikely assumption that the stack emission rates
for PM 2.5 never exceeded the facility P M emissions limit. Given that there may have been multiple excursions to high opacity levels at the Martin Drake plant during this operational timeline, the results of Figure 3 likely err on the side of underestimation of PM 2.5 impacts.

36 American Electric Power Company and Southwestern Power Company have agreed to install PM CEMS, and 30 other existing coal

- fired power pla nts have committed to the use of PM CEMs; from “Petition Requesting that the Administrator Object to Issuance of the Proposed Title V Operating Permit for the Wansley Power Plant

-- Before the Administrator

– United States Environmental Protection Agency;” http://greenlaw.org/pdf/WansleyPetition.pdf.

37 Colorado Department of Public Health and Environment, Operating Permit, Colorado Springs Utilities Martin Drake Power Plant, O perating Permit no. 95OPEP107, e xpiration Date Oct. 30, 2007.

38 Observations by Electric Power Research Institute as reported within “Particulate Matter from Maryland Power Plants,” Prepared for Environment Maryland Research & Policy Center by E. Riddlington, Frontier Group; M. Barrett, Aero Engineering Services; and B. Heavner, Envi ronment Maryland Research & Policy Center; June, 2007.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 14 of 18

303.670.0515 mbarrett@airexpertisecolorado.com Neumann Systems Group Project Appears to Significantly Exceed Cost of Similar SO 2 Control Projects in Colorado yet its Effect s on Air Quality in Colorado Springs are
Unk nown

The Neu mann Systems Group technology was approved by the APCD to meet the Best Available Retrofit Technology requirements of Colorado’s Regional Haze State Implementation Plan. Colorado’s Regional Haze Plan 39 states that:

“Best Available Retrofit Technology (BART ) [m]eans an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant that is emitted by an existing stationary facility. The emission limitation must be established, on a case

- by

- case

39 https://www.colorado.gov/pacific/sites/default/files/AP_PO_Regional

- Haze

- Plan

- Part

- F

- Best

- Available

- Retrofit

Technology_0.pdf

.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 15 of 18

303.670.0515 mbarrett@airexpertisecolorado.com basis, t aking into consideration the technology available, the costs of compliance, the energy and non

- air quality environmental impacts of compliance, any pollution control equipment in use or in existence at the source or unit, the remaining useful life of the source or unit, and the degree of improvement in visibility which may reasonably be anticipated to result f rom the use of such technology.”

Note that emphasis has been added showing that the cost of compliance is one of the key elements in the determination of which technology meets the definition of BART. Consequently, approval of BART by the APCD must rely on its cost effectiveness. Currently, the

t otal installed cost of the Neumann System s Group project is reporte d to be close to $ 200
million ; 40 this figure includes $25 to $ 27.3 million to test the Neumann System s Group pilot project. 41 As a publicly owned utility, these costs will be borne by Colorado Springs Utilities’ ratepayers, i.e., the citizens of the Colorado Springs metropolitan area. Even though requested by citizens, an analysis of how the $200 million Neumann Systems Group technology will affect the ambient air in Colorado Springs has never been performed by either Colorado Spring
Utilities or by the Neumann Systems Group. Nor has APCD required that such an a nalysis be performed showing t he effects of this $ 200 million project on the air quality around the plant, despite this plant’s location within the urban core of the second

- most populous city in
Colorado. 42

Also concerning is that the cost of the Neumann Systems Group technology appear s exorbitant when compared to the cost s of SO 2 control projects implemented at other Colorado coal

- fired electrical generating units. Assuming a n annual SO 2 reduction rate of 9 5 % on Boilers 6 and 7

, and an 80% operational capacity

, the Neumann Systems Group technology will remove

a pproximately 4,750 tons of SO 2 for the plant , annually

. 43 The refore, the cost efficiency, i.e.,
the total installed cost of the Neumann Systems Group control system as a function of the SO 2 reduction that the project will achieve annually, equa ls $42,105 per ton.

40 http://gazette.com/colorado

- springs

- utilities

- works

- to

- clear

- the

- air

- on

- scrubber

- project

- cost/article/1548703

, reports the cost of the Neumann Systems Group project at $170 million. With the added cost of the pilot test project, the total cost is approximately $200 million.

41 Letter, B. McCormick, P.E., Chief Energy Services Officer of Colorado Springs Utilities, to Dr. D. Neumann of Neumann S ystems Group, Inc., March 18, 2011 states $25 million, while two other documents obtained through a Colorado Open Records Act request by L. Weise state $27.3 million for the Neumann test pilot program (2011

- 11 Neumann Reclass Adjustment Summary and CSU Bon d Offering 2012).

42 P opulation of Colorado Springs reported as 445,830; https://en.wikipedia.org/wiki/Colorado_Springs,_Colorado.

43 Assuming a 95% target rate for SO2 removal on Units 6 and 7, and using an average annual rate for both Boilers 6 and 7 of 5,000 tons (from 15,031 tons of SO2 actually emitted from 6 and 7 in the years 2011 through 2013), results in tons of SO 2 removed by the Neumann Systems Group technology of approximately 4,750 tons of SO 2 for the plant.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 16 of 18

303.670.0515 mbarrett@airexpertisecolorado.com Table 3 presents costs and controls efficiencies as reported by the US En ergy Information
Administration for coal

- fired power plants in Colorado. These data show total installed capital
costs of SO 2 control projects (many of which are also likely required by the Regio nal Haze Plan requi rements). An estimate for the tons per year of SO 2 reduced by each project is calculated assuming an 80% operational capacity for each plant and using each project’s reported SO 2 control efficiency. On the basis of t h e s e public reports, when using a similar measure of cos t efficiency for these other Colorado coal

- fired power plants

, i.e., the total installed cost of each
SO 2 con trol project as a function of the SO 2 reduction that each project will achieve annually, the
result s range from $381 to $5,854

, with an average cost of $2,631 per ton 44 compared to the Neumann Systems Group technology cost of $ 42, 105 per ton

.

On the basis of these public reports, the cost to citizen s/ ratepayers C olorado Springs of the Neumann Systems Group technology is on the order of ten or more times that which investors are paying at other Colorado utilities for SO 2 control

. Given that Regional Haze compliance at
the Ma rtin Drake only required that Boilers 6 and 7 reduce SO 2 by approximately 6 0 to 80 % 45

, and given that other utilities in Colorado had implemented cost effective solutions to reduce SO 2 (several likely for the Regional Haze Plan ’ s requirements also) , the following questions must be
addressed for Colorado Springs ’ citizens :

- Why did the APCD approve a system at the Martin Drake that did not take into account cost effectiveness, as required by the Regional Haze rule, when cost effective solutions had been implemented at other coal

- fired power plants in Colorado? 46

- Given tha t natural gas is burned in the B oilers 6 and 7 now, i f natural gas were burned in Boilers 6 and 7 in the future, could dry sorben t injection using trona been implemented at
the Martin Drake ( at a total installed cost that would likely have been on the order of
between 1% to 5 % of the cost of the Neumann Systems Group technology )?

- If the Neumann Systems Group is installed, will it allow the Martin Drake to show modeled compliance with the new 1

- hour SO 2 and NO 2 standa rds and hazardous air pollutant standards ?

These cost comparisons and issues deserve to be discussed in an open setting with regulators

. N o such opportunity for public review and comment have been extended to citizen stakeholders
because the agency continues to allow the plant’s unfettered operation in the absence of a renewed operating permit.

44 Flue gas desulfurization manufact urers for these other Colorado coal

- fired power plants are Babcock and Wilcox, Joy and Peabody.

45 Air Markets reports show rates of 0.4 to 0.7 lb per MMBtu for SO2 for each of boilers 6 and 7 during 2011 through 2013. Reduction to the SO2 r ate of 0.15 lb per MMBtu requires control efficiency in the range of 60 % to 80% fo r the Martin Drake boilers in order to meet Regional Haze requirements.

46 The 500 MW coal

- fired power plant owned by GenOn in Alexandria, Virginia used trona in a dry sorbent injection app lication for approximately a 75% SO2 reduction rate.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 17 of 18

303.670.0515 mbarrett@airexpertisecolorado.com Table 3

– Summary of US Energy Inf ormation Administration Reports of Total Costs and Control
Rates for SO 2 Control Projects Installe d at other Colorado Utilities ( s ince 2000 ).

Due Process Denied to the Citizens of Colorado Springs by the Colorado APCD

The withholding of a draft permit of this major source from public review represents a significant deterioration of the right to public involvement, comment and review that the Clean
Air Act stipulates

. 47 Citizens of Colorado Springs have for many years had no such opportunity

47 Section 500 of the Clean Air Act stipulates that prior to approval of a major source’s operating permit that the public be given opportunity for review.Air Expertise Colorado , LLC

Letter to US EPA

– Martin Drake Nonattainment December 8 , 2015 Page 18 of 18

303.670.0515 mbarrett@airexpertisecolorado.com t o learn of this plant’s impacts and the procedures by which they are calculated

. C omments on the air qual ity impacts of the source are explicitly delineated as required information which the APCD must address as part of the Operating Permit renewal process. 48 Therefore, by withholding a draft permit from public review, the APCD averted any discussion regardin g these unsafe impacts that b oth Wingra Engineering’s and AEC’s analyses describe , and allowed the plant to continue to operate fully without any health

- based constraints. 49 Other i ssues to which
APCD would have had to respond within public review inclu de :

- How does the $200 million Neumann Systems Group project affect the plant’s ability to comply with the NAAQS at public areas immediately adjacent to the plant?

- Since c itizens are spending $ 200 million on the Neumann Systems Group project to
contain Martin Drake’s visibility impacts in Rocky Mountain Nat ional Park (140 miles distant)

– why can’t they learn how the Neumann Systems Group project will affect air quality where Colorado Springs citizens daily recreate, reside and work ?

- How does the 200 mi llion dollars spent by Colorado Springs citizens to reduce SO 2 emissions using the Neumann Systems Group project, compare to the cost of SO 2 control projects that were installed at other coal

- fired electrical utility generators in Colorado? 50

- Why are opa city exceedances allowed at this plant

, at all, in this urban setting where vulnerable populations live, work and play n earby?

- Why isn’t a much lower opacity level (i.e., 10%) required i n this densely populated area ?

- Why are PM CEMs not being used at this plant to assure that PM rates are not exceeded ?

- How do opacity exceedances translate to higher particulate emissions at this plant where

PM 2.5 emissions from the plant and nearby interstate already exceed NAAQS ?

I thank th e US EPA for addressing now these important issue s that bear on the welfare of citizens in Colorado Springs. I will glad ly relay modeling files electronically, if you wish.

Sincerely,

Maureen Barrett, P.E. Air Expertise Colorado, LLC

48 Part C, Concerning Operating Permits, Section VI, Public Participation Requirements. See VI.B.12 stating that “comments that are solicited on the air quality impacts of the source or modification” must be information that is included on the Division’s we bsite on which the renewal notification is posted.

49 None of the pla nt’s operating permit rates derive from an analysis of the plant’s impacts on the surrounding area.

50 For the Trans Alta plant in Washington, the utility paid $190 million in capital c ost s to control SO 2 in 2002/2003 on two boilers. This system reduced SO 2 by app

. 80,000 tons per year. CSU estimates their SO 2 control project cost as $ 200 million on two boilers, for a system that will reduce SO 2 by app. 4,500 tons per year. http://www.ecy.wa.gov/programs/air/TransAlta/Final_agreement/Transalta_signed_agreement.pdf

.Attachment 1

– Under Separate Cover

Letter

- AEC to Interim Deputy Director K. McGowan

– September 23, 2013