1 Addendum Responding to Questions Received

Question Response 1. Wh ere are the EPA designated Class I park areas to be protected by this EPA proposal? EPA did not designate Class I areas. These were designated by Congress (see section 162(a)). The Class I areas relevant to this rulemaking are identified in Table 8 of the proposal ( Caney Creek Wi lderness Area (AR), Hercules Glades Wi lderness Area (MO), Upper Buffalo W ilderness Area (AR), and Wi chita Mountains Wi lderness Area (OK)

. 2. How and with what authority and with what State input were these parks designated as Class I areas? As noted above, Class I areas were designated by Congress.

3. How far and in what direction is each of these parks from the specific Oklahoma OGE and PSO coal

-fire d power plants targeted by this EPA proposal? Distances can be found in Appendix B, Table 1

- 1 of the Technical Support Document (TSD). Maps provided in the TSD indicate direction. Please see Figure 1

- 1 in Appendix B of the TSD. 4. How many other coal

-fired power plants of what size are located closer to or at similar distances from the parks in question? For the FIP EPA evaluated the BART eligible sources within Oklahoma. Table 2 of the proposal lists Oklahoma’s BART eligible

sources

. For th is rulemaking

, EPA did not identify other BART eligible coal

-fired power plants located closer to or at similar distances from the Class I areas within Oklahoma

. Other non

BART eligible coal

-fired power plant sources are: Grand River Dam Authority Chouteau Plant, Unites 1 (520 MW) and 2 (490 MW ), in Mayes County Units 1 and 2 in Mayes County ; We stern Farmers Electric Cooperative, Inc. Hugo Plant, Unit 1 (446 M W) in Choctaw County ; OG&E Muskogee unit 6 (572 M W) ; and AES Shad y Point a coal

-fired cogeneration plant (2 units, 320 MW total) in Le Flore County

. 5. From EPA's modeling analyses on how many days is visibility expected to be diminished in each park area and to what extent is it expected to be diminished on these days? See our Response to Modeling Comment #1 in the final rulemaking for the number of days visibility impacts from an individual facility’s BART units is over 0.5 deciviews a nd 1 d eciview

. 6. In what seasons are these "impact days" expected to occur at each park and how many of these days are single days compared to continuous multiple days? Observed and modeled visibility impacts, as well as day of the year, for each of the 20% worst days in 2002 are provided in Figure 4

- 8 of Appendix A of the TSD and A ppendix D of the CENRAP TSD

. Wenote that the monitor takes a sample every three days , year round . In modeling for individual source impacts on a Class I area, we examine the 98 th percentile or 8 th highest2 impacted day consistent with the BART guidelines

. 7 . Has EPA provided "Seasonal Wi nd Roses" that would allow Oklahoma citizens and officials to understand how and when the targeted power plants could affect these remote parks that most people would not consider to be downwind of these plants? As di scussed in the TSD, CALPUFF visibility modeling was performed using three years of prognostic meteorological data. This meteorological data is more sophisticated than wind rose data. In modeling for individual source impacts on a Class I area, we examine the 98 th percentile or 8 th highest impacted day consistent with the BART guidelines. Because we evaluate visibility impairment on a 24

- hr basis, seasonal wind patterns were not directly considered in our decision. Pleas e see Appendix W of 40 CFR 51 ( Gu i deline on Air Quality Models, 8.3.1.2 (d) ). 8 . For each park how many visitors are expected by season currently and how many are forecast by season for various future years? EPA does not forecast the number of visitors to Class I areas

. T his factor is not considered under Section s 169A and 169B of the CAA or the RH rule

. 9. Wh at additional annual and total costs does EPA believe wil l be required for OGE and PSO to comply with EPA's proposal? As part of the FIP, this action includes a thorough evaluation of the cost of compliance for the six units. EPA’s evaluation includes both annual and total costs in accordance with guidance and the RH rule. See the revised Cost Estimates included in this final rulemaking. 10 . Since these costs must be paid by Oklahoma's electric ratepayers for each utility, how much additional annual cost does EPA expect must be paid by each ratepayer/customer for each utility? EPA does not have expectations of what costs must be paid by each ratepayer/custom er for each utility because the CAA and the RH rule do not contemplate this factor as part of the BART analysis

. 11 . Con s idering the additional annual costs for OGE and PSO compliance compared to the current and expected visitor days in which visibility would be expected to be impacted (i.e. "visitor impact days"), what does EPA consider to be the effective cost per potential "visitor impact day"? As required by the CAA, EPA has considered, among other things, the cost of compliance and expected visibili ty improvement. W hile EPA believes the controls to be cost effective, EPA has not estimated an effective cost per potential "visitor impact day”. The CAA and the RH rule do not proscribe that states or EPA estimate a benefit of removing “visitor impact d ay.” Instead, the RH rule quantifies improvement in visibility using the deciview as the unit of measurement. For additional information on the visibility improvement of this FIP, see our responses to the Modeling Comments in the final rulemaking and the TSD. 12. Wh at is the estimated benefit of removing these "visitor impact days"?

13. Wh at is the ratio of the Cost to the Benefit of this EPA proposal? The CAA requires our BART analysis to evaluate both the cost of compliance and the degree of improvement in visibility resulting from the addition of controls. As directed by Congress, EPA is obligated to consider in determining BART (1) the costs of 14. Does EPA feel an obligation to consider the Cost/Benefit Ratio in its decision to proceed with this Regional Haze proposal which3 only relates to aesthetics and not to health? comp liance, (2) the energy and non

-air quality environmental impacts of compliance, (3) any existing pollution control technology in use at the source, (4) remaining useful life of the source, and (5) degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology . CAA section 169A(g)(2). For more information on this evaluation, see the TSD and the revised cost evaluation. As stated above, the CAA and the RH rule do not provide for a Cost/Benefit analysis that the commenter describes. 15. Has EPA estimated a fraction of the year the emissions would need to be controlled at each of the targeted plants to meet these regional haze objectives? Under 40 CFR section 51.301, Best Available Retrofit Technology (BART) means an emission limitation based on the degree of reduction achievable through the application of the best system of **continuous emission reduction** for each pollutant which is emitted by an existing stationary fac ility. Consistent with the definition of BART in 40 CFR 51.301, we evaluated controls based on continuous operation. Therefore, u pon the effective date of our rule, the regional haze controls that will be necessary to meet the SO 2 BART emission limit of 0.06 lbs/MMBtu at the six OG&E and AEP/PSO units must operate continuously whenever the units are generating electricity. Please see the federal register notice associated with the rule for more detail. 16. Has EPA considered the adverse regional economi c impact and the adverse impact on O klahoma's economy that would result from this proposal? After careful review of cost and visibility benefits EPA determined that controls are cost effective . O ur evaluation found that compliance costs would be significa ntly less than estimates provided by the State of Oklahoma

. 17. Has EPA fully considered its moral and legal authority under the Clean Air Act that would provide the confidence that it would prevail in the courts on its decision to overrule Oklahoma's state's rights by rejecting the plan, and even by the earlier designation of these three Class I air quality areas and even the continuation of the national parks if the states object to these designations? EPA has fully considered its authority and obligations in undertaking this rulemaking. EPA has a mandatory duty under the CAA to act on Oklahoma’s RH SIP. Because we have determined that portions of the SIP are not adequate to meet the requirements of the CAA and federal regulations, EPA is obligated to partially disapprove the SIP and implement a FIP. As stated above, Congress designated the Class 1 areas in CAA section 162(a). EPA has no authority over the continuation of national parks.4 Questions rel ated to the Wi chita Wi ldlife Refuge Response 1. Wh at study has been done to determine what part of that haze is caused by the natural emittents from the trees and the fauna in that area? Section 6 of Appendix A of the TSD discusses the types of source categories, source regions and polluta nt species that contribute to visibility impairment at W ichita Mountains. Emissions from biogenic sources, motor vehicles, agricultural activities and other area sources are all included in the emission inventories used to model and project visibility con ditions.

As discussed in the TSD, CALPUFF visibility modeling was performed using three years of prognostic meteorological data. In modeling for individual source impacts on a Class I area, we examine the 98 th percentile or 8 th highest impacted day con sistent with the BART guidelines. Please see Appendix Y of 40 CFR 51. 2. Wh at study has been done to determine how much of the haze is caused by the artillery firing at Fort Sill? 3. H ow much of the haze has been caused by highway traffic in Lawton and wh at study has proven this. 4. How much of the haze has been caused by farmers plowing and the dust that will create haze in the air. 5. How much of the haze has been caused by coal

-fired plants or any kind of plant in Texas which is south down or upwind from the prevailing winds that blow in Oklahoma?

6. I would really like to understand how those pollutants, those so

called pollutants from the clean burning coal

-fired plants in Oklahoma that are under discussion, how can that pollution travel that 200 miles against the prevailing winds to create that haze there?