1 Shoshone Bannock Tribes Air Quality Department

- 6/21/12

Comments on EPA’s Proposed Approval of Idaho’ s Regional Haze SIP

Docket ID No. EPA

- R10

- OAR

- 2010

- 0930
Submitted by email to: R10

- Public_Comments@epa.gov
Identification of four factor analysis

- Idaho needs to demonstrate that it is making reasonable progress in reducing anthropogenic emissions within the State, especially with resp ect to non

- B ART sources in Eastern Idaho. Within the I

- SIP, neither the Simplot Don Plant, a wet

- phosphoric acid plant and sulfuric acid plant, the Agrium plant nor the Monsanto (or ”P4) plant, we re detailed enough to report BART and Non

- BA RT emissions of Haze pollutants within their plants.

a. In the case of the Simplot Don Plant, though facts presented are sketchy, the I

- SIP reported that the most significant sources of Haze pollutants were non

- BART sources within the plant. WRAP
rep o rted 31 separate emi ssion sources within the plant. Hence, the I

- SIP should have carried out the 4 factor

– Reasonable Progress A n alyses of this plant, as required by 40 CFR 51.308(d)(1)(i) and Section 169A of the Clean Air Act. This plant is large and has operated with few process changes over the years and has been well characterized and permitted by IDEQ. The 2007 toxic release inventory is as follows:

State Facility Identifier Pollutant

Code 2007 TPY

07700006 CO 45.40

07700006 NH3 116.30

07700006 NOX 112.33

07700006 PM10

- PRI 211.39

07700006 PM25

- PRI 211.29

07700006 SO2 1,610.72

07700006 VOC 3.30
From the above inventory this source emits 4 tons per day of sulfur dioxide

. This release inventory is typical of Simplot’s annual emissions. In view of the potential significance of this source, particularly on impact s to visibility within Craters

- o f

– the Moon National Monument , Teton and Yellowstone National Parks , the I

- S IP shou ld have detailed emission sources and emission values within the plant, potential control technologies, and regulatory plans to limit these non

- Bart emissions.2

Unfortunately the I

- SIP st ated that IDEQ needs more time to do so

. But the State of Idaho was late in their SIP to begin with and failed to submit any of the required reg ional haze SIP elements at 40 CFR § 51.308. These elements were required to be submitted no later than Decemb er 17, 2007. (The EPA Federal Register of May 22, 2012, is remiss in not discussing this, in considering approving the Idaho Haze SIP.)

Had the State of Idaho submitted t heir Haze SIP on time, they likely would have had time to complete the 4 factor analyses of large point s ources. The State of Idaho’s Haze SIP should not be approved by EPA w hen there are these point sources, such as phosphate plants in eastern Idaho that emit large amounts of haze producing pollutants, and when the State is no t following F ederal haze regulat ory deadlines, and when the SIP is n ot adhering to the four part Reasonable Progress Analysis requirements of Section 40 CFR308(d)(1)(i), of Simplot Don Plant, as well as other point sources. In view of the above factors, the EPA should not approve the S tate of Idaho’s Haze SIP.

Reason for Reasonable Progress Analyses Delay

- Additional information has been made available that indicates Idaho’s reason for delay, in the case of the Simplot Don Plant ’ s, 4 factor analysis, is inaccurate. That is, the I

- SIP requests 5 years more time for Sulfuric Acid plant analysis (two years for modeling, and 3 year s to install emission controls )

. However, the Simplot Don Plant recently applied for a p ermit to construct an improved sulfuric acid plant wherein, they h ave indicated a one year time

- table for installing an improved (BACT) scrubber at the Sulfuric acid plant

- underscoring the unreasonableness of the I

- SIP with respect to implementing control technology. ( Reference: Simplot, Permit

- To

- Construct, for 400 Su lfuric Acid Plant, Prepared by RTP Environmental Associates, Inc., December 2011. ) So, the projected 3 years for installing emission co ntrols at Simplot is erroneous, just as the 2 year modeling schedule for these large sources is unreasonable. (Idaho re quires sources to carry out modeling as part of their permit application.) EPA should require Idaho to complete the Reasonable Progress Analyses on a realistic schedule and no t approve the existing Haze SIP which has an unreasonable delay in implementatio n of four factor analysis for Non

- BART sources.
Moreover, it appears that the State of Idaho, in their Haze SIP is not only requesting an unreasonable time

- table for compliance as reviewed by EPA in this initial review, but by unreasonably projecting another 5 year delay is attempting to also establish the possibility that Simplot and other point sources may not be ready for emission reductions in time for the next 5 year review period! ( 40 CFR 51.308(i)(1)(4) requires five

- year progress reports.) Th is is unacceptable and EPA should review this issue and require IDEQ to revise the Haze SIP accordingly.
Nu West/ Agrium

- This source of emissions is inadequately c overed in the I

- SIP. T he individual plant emission sources and emission estimates for ea ch source should be provided in the Haze SIP, as well as more discussion of BART eligibility. For those sources that are non

- BART, the I

- SIP should3

provide a four point Reasonable Progress Analyses of the sources and control technology as required under 40 CFR 51.308 (d)(1)(i)(A). The I

- SIP is totally inadequate with respect to analyzing this large sourc e of haze

- generating pollutants and EPA should require a revision of the HAZE SIP to complete the 4 point analyses of this plant, and including a review of emissions and emission controls.
Crop Residue Burning

- The I

- SIP does not adequately analyze crop residue burning impacts to Class I air

- sheds, rather the I

- SIP merely states that the program was approved by EPA. But the controversial crop residue burning in Idaho may impact Class 1 areas, and has not adequately been reviewed in the I

- SIP. The I

- SIP is estimating a 54% reduction in anthro pogenic fires. Yet, from the period betwe en 2002 to present, there has been a significant i ncrease in agricultural burning: 44,280 acres were burned on state lands in 2002 (Source: 2002 Idaho Agricultural Smoke Management Program Statewide Summary, Februar y 26, 2003) and for the 2011 year

– a significant source of haze producing pollutants unrecognized in the Haze SIP. The primary strategy of permitting crop residue burns (and prescribed burns) is to disperse the smoke by prevailing winds. While it is tru e that smoke is reduced in down

- wind concentration by this strategy, given the large acreages being burned, it increases haze on a regional scale and increases haze impacts in down

- wind Class 1 areas, especially in the fall when field burning is scheduled. The resulting haze should be reviewed, and modeled by I

- SIP, included in the long

term strategy.

5.8 Long

- Term strategy

- In t his section of the I

- SIP it lists “ Smoke management techniques for agricultural and forestry burning, including plans to red uce smoke impacts.” The IDEQ allows prescribed and agricultural burns to take place without regard for regional haze, in fact the entire strategy of “Smoke Management” in IDEQ rules is to avoid smoke accumulating close to the burn, and allowing it to be dispersed farther down

- wind. That is, promote burning when conditions disperse the smoke to a regional

- based impact, while avoiding impacts close by. With over 44,000 acres being burned annually, the I

- SIP should address the Long Term stra tegy of Agricultural Burning, because it increases haze at C lass I areas. T he I

- SIP should make plans to model these recently allowed “Crop Residue Burns” and Prescribed burns; and begin planning for better emission controls to protect Class 1 areas. Crop residu e burning is increasing with the advent of the relatively new “Crop Residue Burning” section of IDEQ’s Rules.
Consultation with Federal Land Managers and Wyoming
Federal Haze rules require consultation with Federal Land Managers and neighboring States. The I

- SIP did not provide enough detail of Wyoming’ s comments and consultation. Neither did the I

- SIP discuss resolving comments submitted by the National Park Service and U.S. Forest Service. This should be reported in more detail.

Summary

The EPA sh ould reconsider their approval of Idaho’s Haze State Implementation Plan (SIP). This I

- SIP, was years late to begin with, and yet with this submission the IDEQ, failed to fulfill the4

requirements at 40 CFR section 51.308...again stating that they did not ha ve time. As a consequence a critical section of the Haze SIP plan is incomplete, with Reasonable Progress Analyses and controls left undone at large point sources in Idaho that impact Class 1 areas. As an example of this deficit, the Simplot Don Plant, h as few BART sources, but most of their emission inventory is non

- BART sources that adversely impact visibility, but for which Idaho failed to complete the needed four point factor analysis. Other point sources have similar deficits in carrying out Reasona ble Progress analysis.
Field burning within Idaho may adversely impact Class 1 areas and Idaho’s Haze SIP did not adequately review impacts (short

- term or long

- term) to Class 1 areas, nor did it accurately describe the permit program which seldom, if eve r denies burns that might impact National Parks or Monuments: That is, the permit program is largely a registration program rather than a program with realistic tools to monitor Class 1 impacts, let alone limit Agricultural

- based burns to safeguard Class 1 airsheds.
In consideration of this issue the EPA should disapprove the d raft Regional Haze SIP of Idaho and request a fast track by the IDEQ to revise the Haze SIP. To do otherwise is counter to the Clean Air Act (Section 169 A ) and results poorly controlled emissions of haze producing pollutants reaching Class 1 areas of Idaho and Wyoming.
Thank you for this opportunity to comment on this important step by EPA to reduce regional haze in the west.

Regards,

Roger Turner Interim Air Quality Manager Shoshone

- Bannock Tribes P.O. Box 306 Fort Hall, ID 83203 airquality@sbtribes.com