PO Box 71249, Fairbanks, AK 99707-1249 • (907) 452-1151 • www.gvea.com 

Your Touchstone Energy• Cooperative ~ 

March 23, 2012 

Via Electronic and Overnight Mail Delivery 

EPA Region 10 

1200 Sixth A venue, Suite 900 

Seattle, W A 98101 

Attention: Keith Rose, Office of Air, Waste and Taxies, A WT -107 

Re: Docket ID No. EPA-R10-0AR-2011-0367 

Dear Mr. Rose: 

Golden Valley Electric Association ("GVEA'') appreciates this opportunity to respond to the 

U.S. Environmental Protection Agency's ("EPA's") comments on the Alaska Regional Haze 

State Implementation Plan ("SIP"), published in the Federal Register on February 24, 2012. 

GVEA submits this letter documenting our comments and concerns as part of the record for 

Docket ID No. EPA-R10-0AR-2011-0367. 

GVEA offers comments on the State of Alaska's ("State" or "Alaska") sources of visibility 

impairment in Denali National Park, Alaska's consideration of emissions from Healy Power 

Plant Unit No. 2 in its reasonable progress evaluation, and the Best Available Retrofit 

Technology ("BART") determination for Healy Power Plant Unit No. 1. 

Sources of Visibility Impairment 

In its discussion of sources of visibility impairment in Class I areas, EPA proposes to accept, 

among other things, Alaska's analysis of the impact of identified pollutants on visibility in 

Denali National Park. Alaska's analyses conclude that natural wildfires are the dominant source 

for all of the visibility impairing pollutants registered at both monitoring sites for Denali 

National Park. GVEA agrees with EPA and Alaska that natural wildfires inside Alaska are the 

primary contributors to regional haze at Denali National Park. GVEA also submits that the 

sources outside and upwind of Alaska are significant contributors to visibility impairment, and if 
EPA Region 10 

March 23, 2012 

Page 2 

visibility is not improving as planned, the monitoring data should be evaluated to quantify not 

only the impacts from natural wildfires, but from the out-of-state, upwind air pollution as well. 

Reasonable Progress Evaluation and Consideration of Healy Power Plant Unit. No. 2 

GVEA agrees with Alaska and EPA that the exact amount of impact from any operation of Healy 

Unit No.2 cannot be determined at this time. 77 Fed. Reg. 11036 (Feb. 24, 2012). We also 

agree with Alaska and EPA that it is not reasonable to require additional controls on the unit. 

However, GVEA does not agree with the State's assumption that it will necessarily have to 

"consider" Healy Unit No. 2 in its reasonable progress evaluation. 

First, the requirement for revising an implementation plan becomes applicable only after a state 

determines that there is a need for revision based upon the comparison of the visibility monitored 

versus the glide path projected. 40 CFR 51 .308(g) - (h). If the glide path projection is being 

met, there is no need and no requirement to revise a state's Long Term Strategy ("LTS"). At 

present, "the RPGs for Class I areas are projected to meet the URP in 2018." 77 Fed. 

Reg. 11036 (Feb 24, 2012). Therefore, assuming that Healy Unit No.2 will need to be 

considered at all in Alaska's reasonable progress evaluation is at best premature. Nor will 

Alaska's estimate of an increase of NOx by a factor of 4.0 and of SOx by a factor of 2.8 (should 

Healy Unit No. 2 begin operating) support the assumption that the glide path will not be met. 

The increased emissions estimate is based on permitted, not actual emissions, and it assumes 

Healy Unit No.2 will operate at full capacity, that all other sources will continue to operate 

exactly as measured during the baseline period, and that no new sources will be brought on line. 

Such assumptions cannot be the basis for a current decision that Healy Unit No. 2 will need to be 

considered in the future, particularly when actual emissions data would be available and other 

factors will likely change. 

Second, if Alaska determines that the current regional haze SIP is inadequate to meet RPGs, the 

Regional Haze Rule does not support the State singling out Healy Unit No. 2 during a reasonable 

progress evaluation. If the visibility goals are not being met, the Regional Haze Rule requires 

that the implementation plan be revised by reviewing all sources of visibility impairment and 

determining the best way to improve visibility given economic, energy and non-air quality 

environmental impacts of compliance, the remaining useful life of any affected existing source, 

as well as the effect of new sources. 40 CFR 51.308(f). Healy Unit No. 2, along with other 

stationary sources, may be included in the evaluation for a revision of the implementation plan if 

the RPGs were not being met and Alaska determined that stationary sources within the United 

States were a significant cause of the visibility impairment. 

Third, as previously noted in these comments, EPA states that sources outside the country are 

significant contributors to regional haze at Denali National Park. When discussing 

transboundary emissions from outside the United States, "[T]he EPA does not expect States to 

restrict the emissions from domestic sources to offset the impacts of international transport of 

pollution." 64 Fed. Reg. 35736 (July 1, 1999)(40 CFR 51.102 AND 51.103). Moreover, if "the 
EPA Region 10 

March 23, 2012 

Page 3 

implementation plan is or may be inadequate to ensure reasonable progress due to emissions 

from sources in another country, the state shall provide notification, along with available 

information, to the Administrator." 40 CFR 51.308(h)(3). GVEA agrees with EPA that 

domestic sources should not be used to offset international impacts and, under the Regional Haze 

Rule if Alaska's implementation plan were inadequate because of upwind, out-of country 

sources, the State of Alaska would not be required to revise its plan. Therefore, GVEA requests 

that if an evaluation is required during any 5 year progress report, that Alaska carefully and 

quantitatively measure the impacts from international transport on visibility, clearly identify 

reductions from domestic stationary sources and demonstrate that any required reductions from 

domestic stationary sources are not offsets for international transport impacts. 

Healy Power Plant Unit No. 1 

Regarding Healy Unit No. 1, GVEA agrees with Alaska and EPA that the BART determination 

for Healy Unit No. 1 does not result in a state or federally enforceable shut down of Healy Unit 

No. 1 in 2024. GVEA also agrees with Alaska and EPA that the BART process results in an 

emissions limit for NOx based on the limit that can be achieved with Selective Non-Catalytic 

Reduction ("SNCR") and that Selective Catalytic Reduction ("SCR") would not be cost 

effective. 

Although GVEA agrees with the agencies that SCR would not be cost effective, GVEA submits 

this comment to address EPA's characterization of Alaska's determination. In particular, EPA 

indicates that Alaska's determination was inappropriately based on an 8-year period and that, in 

the absence of a federally-enforceable shutdown date, Alaska should have considered a 15-year 

period. Alaska, through its contractor Enviroplan, considered both periods and found SCR cost 

prohibitive for both. In the Enviroplan Final BART Determination Report for GVEA 

(January 19, 2010), Enviroplan states "It is nonetheless noted that the site-specific SCR 

[Selective Catalytic Reduction] cost evaluation performed by Fuel Tech ... has resulted in SCR 

being determined as cost ineffective, irrespective of the amortization period used in the cost 

analysis." Final Report at 16. 

In conclusion, GVEA would like to thank the EPA for the opportunity to review the proposed 

approval of the Alaska Regional Haze SIP. We look forward to revisions of the proposed 

approval. 

Environmental Officer