United States Department of the Interior 

ASH AND WILDLIFE SERVICE
 

National Wildlife Refuge System
 

Branch of Air Quality 

IN REPLY REFER TO: 7333 W. Jefferson Ave., Suite 375 

Lakewood, CO 80235-2017 

FWSIANWS-AQ 

March 15,2012 

Monica Morales, Unit Chief 

Air Quality Planning Unit 

Air Program 

U. S. EPA, Region 8
 

1595 Wynkoop Street
 

Denver, Colorado 80202-1129
 

Dear Monica: 

On March 2 and March 5, 2012, we received from the Environmental Protection Agency, 

Region 8, draft sections of the Regional Haze Federal Implementation Plan for the State 

of Montana. The U.S. Fish and Wildlife Service (FWS) and National Park Service (NPS) 

appreciate the opportunity to review and comment on this draft plan prior to public 

notice. Due to very short time available for review, we are focusing our comments to a 

limited number of highlighted items. We intend to comment more fully during the public 

notice period. 

Our enclosed comments reflect the discussion we had with you and EPA Region 8 staff 

on our conference call March 14, 2012. We continue to be concerned that EPA has not 

defined objective criteria for the determinations of Best Available Retrofit Technology 

and reasonable progress that support which emissions controls are cost effective and what 

level of visibility improvement is necessary to justify emission control costs. While our 

enclosed comments address your analysis of Corette Generating Station, we have 

concerns about the conclusions drawn for several facilities that are located adjacent to our 

Class I areas. We also have recommendations on the presentation and interpretation of 

the emissions inventory and regional modeling data that are the basis of the reasonable 

progress goals set for Montana Class I areas. 
2 

We appreciate the opportunity to work closely with EPA Region 8 to improve visibility 

in our Class I areas. For further information regarding our comments, please contact Tim 

Allen at (303) 914-3802 or Pat Brewer at (303) 969-2153. 

Sincerely, 

~~C£
 Sandra Silva, Chief Carol McCoy, Chief
 

Branch ofAir Quality Air Resources Division
 

U.S. Fish and Wildlife Service National Park Service 

Enclosures 

cc: Dave Klemp, Chief 

Air Resource Management Bureau 

Montana Department of Environmental Quality 

1520 E. Sixth Avenue 

P.O. Box 200901 

Helena, MT 59620-0901 
Comments to EPA Region 8 on Draft Federal Implementation Plan for Montana
 

March 14,2012
 

The U.S. Fish and Wildlife Service (FWS) and National Park Service (NPS) appreciate the 

opportunity to comment on the Environmental Protection Agency (EPA) Region 8 draft proposal 

for the Montana regional haze Federal Implementation Plan (FIP). Due to the very short review 

time available, we are focusing our initial comments on a limited number of highlighted items. 

We intend to continue our collaborative review throughout the public comment period. 

Organization 

In general the proposed FIP contains an accurate summary ofthe regional technical analyses 

provided by the Western Regional Air Partnership (WRAP). We recommend that EPA define 

the state inventory and source contributions at Class I areas in Montana and neighboring states, 

based on the WRAP regional data, before discussing the source-specific analyses for Best 

Available Retrofit Technology (BART). This would provide the context for overall contributions 

before focusing on those specific point sources in Montana. As presented, the emissions 

inventory and source apportionment data are lost as short sections between detailed discussions 

of source specific BART and source specific reasonable progress analyses. We suggest moving 

the first three sections of section D: Long Term Strategies, to become section C: Emissions 

Inventory and section D: Sources of Visibility Impairment (section Dl: Montana Class I areas, 

section D2: Other States' Class I areas Affected by Montana Emissions). Then continue 

reordered section E: BART Determinations and reordered section F: Long Term Strategies 

starting with subsection Fl: Visibility Projection Modeling. 

Emissions Inventory 

We agree with EPA's conclusion, based on WRAP's emissions inventory and source 

apportionment modeling, to focus on point source emissions of sulfur dioxide (S02) and nitrogen 

oxides (NOx). Given that point sources are the largest sector for S02, EPA should explicitly state 

that WRAP analyses projected that S02 emissions in Montana from this sector would decrease 

by less than 1 percent by 2018. Please state that WRAP inventory assumptions include both 

presumptive S02 reductions for Colstrip Units 1 and 2 that are subject to BART, and S02 

increases due to new electric generating capacity by 2018. Please clarify if the projected new 

facilities are still expected by 2018. If not, please clarify that S02 emissions will be reduced 

more than reported in Table 140. 

On page 166, supporting Table 141, EPA explains that the WRAP assumed 23,000 tons ofNOx 

would be reduced at Colstrip by 2018 due to an enforcement action and additional controls 

required by the Regional Haze FIP. Please add an explanation what fraction of the 23,000 tons 

assumed for NOxemissions reductions at Colstrip will now be required under BART and the 

enforcement action. Since EPA's proposed reasonable progress goals are based on the WRAP 

modeling, EPA needs to clarify what reductions are actually being implemented. Also, please 

address whether WRAP assumptions for new electric generating capacity by 2018 are still valid. 

1 
Uncertainties Associated with Oil & Gas Development 

The Oil & Gas sector is going through a period of rapid change with large areas of significant 

growth. This growth has considerable cumulative impact potential to visibility at Class I areas 

across Montana and at nearby States. The emission inventory utilized by WRAP is severely out 

of date for this sector and does not represent the full impact potential. We ask that additional 

discussion be included in the FIP proposal addressing this activity. We also request that this 

issue be identified as one that will be addressed as part of the upcoming five year review. 

Best Available Retrofit Technology (BART)
 

We request clarification on the criteria used to determine what costs or visibility benefits were
 

considered in evaluating reasonable controls. Through our review, we compared metries relating
 

costs to emissions controlled, and costs to visibility improvement, and found inconsistencies. A
 

number of States, in establishing their control decisions for BART or RP, have identified
 

consistent criteria for source controls. The draft FIP in some cases found controls not to be cost
 

effective, even when the $/ton was lower than controls on other units that were found to be cost
 

effective. Some controls were found not to be justified by the visibility improvement even
 

though the $/dv cost effectiveness was lower than for controls that are being required. Since
 

some of the review materials are still outstanding, we understand that we may not have the full
 

description of control evaluation at this time. We request your assistance in clarifying this issue.
 

Cumulative visibility benefits at multiple Class I areas should be considered when evaluating
 

cost effectiveness of control options. EPA presented visibility benefits for all Class I areas in the
 

BART analyses, but compared costs to maximum visibility benefit at a single Class I area.
 

PPL Montana's J. E. Corette Generating Station
 

FWS commented in the attached document on the BART determination for the PPL Montana J.
 

E. Corette Generating Station. The confounding factors of a relatively smaller unit size (162 

megawatt (MW» and very low-sulfur coal (Powder River Basin (PRB) 0.3% sulfur 

content/uncontrolled emission rate of 0.46 Ibs/MMBtu) constrain the cost-efficiency of control 

alternatives. Nevertheless, as discussed in the attachment, there are control alternatives for both 

S02 and NOx control that we consider to be cost effective, even though EPA eliminated these 

controls as BART. In the attachment we discuss several examples of BART determinations in 

the cost range of controls for Corette. 

Columbia Falls Aluminum Company 

We request that EPA strengthen the discussion ofthe BART requirements for Columbia Falls in 

the FIP proposal and provide notice to the company that if the facility were to restart, a BART 

analysis would be required. The facility shut down in 2009 and is currently not operating, but is 

negotiating a power service agreement with Bonneville Power to be able to restart at least 

partially. Columbia Falls is only 10 km from Glacier National Park, and preliminary WRAP 

modeling using 2002 emissions indicated more than 4 dv visibility impacts at Glacier. Ifthe 

company will be restarting, a BART analysis to evaluate emissions reductions to reduce visibility 

impacts should be part ofits planning process. The current text is not clear whether the source 

would be required to perform BART before or after restarting. 

2 
Reasonable Progress Analyses 

EPA identified point source emissions of S02 and NOx as the most important sector to consider 

for reasonable progress, and yet required only Devon Energy to reduce emissions. EPA 

determined that costs are excessive for all sources except Devon Energy, yet the costs that were 

determined to be excessive are lower than costs determined to be reasonable for BART sources. 

Please explain. 

For the reasonable progress screening criteria, please add clarification to the text (see page 186) 

that emissions (Q) is annual tons ofS02plus NOx. 

Reasonable Progress Goals 

EPA is proposing reasonable progress goals for the 20% worst visibility days for the Montana 

Class I areas that are significantly less than (16-51 %) the uniform rate of progress (page 284). 

EPA needs to pay careful attention to the precedent set by justifying the proposed reasonable 

progress goals. EPA cites the contribution of natural sources and emissions from Canada and 

outside the modeling domain as the basis for concluding that it is reasonable to rely on existing 

controls and the BART reductions to demonstrate progress in Montana. EPA again cites costs of 

controls for non-BART sources as excessive even though the costs are lower than being 

implemented for BART. 

On page 287, EPA would like to state that the emissions reductions under EPA's proposal are 

greater than the reductions modeled by the WRAP. We agree that EPA needs to reconcile actual 

requirements with WRAP's assumptions for 2018 emissions in order to demonstrate that 

emissions reductions in Montana are meeting the implicit commitment to the other WRAP states. 

It is not likely that the actual rate of progress will be significantly closer to the uniform rate of 

progress than the WRAP modeling projections, as EPA states on page 287. 

Several western states have used separate glide paths for each visibility impairing pollutant as 

added weight of evidence to demonstrate that the state is making reasonable progress on the 

pollutants that are controllable by the states. In the case of Montana, it is hard to make this case 

when only slight reductions in sulfate are projected by 2018. Results illustrated in enclosed two 

figures are representative of Montana Class I areas. We would like to discuss this further with 

EPA. 

Additional information on the Montana Smoke Management Plan (SMP) 

According to the draft FIP, the State submitted an updated version of its SMP on February 17, 

2012. Although not available for review, we are encouraged by the commitment to consider 

visibility impacts when, "developing, issuing or conditioning permits and making dispersion 

forecast recommendations." However, it is not clear whether the SMP incorporates best 

management practices (BMPs), emission tracking, or enhanced practices to minimize impacts, as 

discussed by the Western Regional Air Partnership (WRAP). More specifically, the draft does 

not indicate whether Class I areas are considered sensitive receptors. Identifying Class I areas as 

sensitive receptors in an SMP is an important component in connecting the SMP to the regional 

haze FIP. We request that you include statements to the proposal indicating whether the SMP 

addresses these additional attributes. 

3 
Sultf>!e 

-+Nitrate 

-+Particulate Organic Mass 

-+Elemental Carbon 

-+So~

---~.-------- ! 

--------.------ -------. -..---­ ~0--l

---==....::::­

Consultation 

EPA was not able to provide Federal Land Managers sixty days review. We received and 

reviewed PIP materials within the past three weeks, with substantial portion available for less 

than a week. Additionally there are outstanding technical questions. We understand the 

timelines that EPA is facing, and are trying to accommodate as best as possible. However, under 

the circumstances, we do expect to submit additional, detailed comments during the public 

reVIew process. 

r---------------.------------GatesOfthe Mountains W MT C1asslarea --------------------------.--------------I 

i Projected 2018 PRP18a Visibility Conditions on Worst 20% Visibility Days from Plan02d 

, EPA Specific Days 

I ::: t=---,~~_=:=.-=-~~~:=:-:~- -_:=~-_:: -=-~=--:-: i 90 [-- -------- - ----- -- - ------- I 

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I 1 0 -1---- ! . , I .... 2005-09 Progress Average i 

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i------------·-~~~c1ed~:~~p~P1:~~~~b~~~:~:~~:~:r~l~t[~~~I~:~ayS ~:~ :~::~=:----.----.---- -.----.---.-------.-i I EPA Speclllc Days , I 14.0 .--.---.-.-....-. . ..---..---------------.. --.-...--.--.----.., , 

, I .... 13.3 41 2.9 

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- 2000-04 Baseline Average 

j 201--- -2~1.:::.:.:..:2:.3~-:·-: .. ====;;;;;;:====::==:~~~ .... 2005-09 Progress Average ..-~ti.7-:.. i L M S I 0.0 ---'-. -----.. --.-~.---.------,--- ..-----.--.---.--.-._------.-,-------' o 2064 Natural Condalons 

. 1990 2000 201 0 2020 2030 2040 2050 2060 2070 i__. .__. . . . ... . .. ! 

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'11 I I~- BD i'" -'8, 

4
 
u.s. Fish and Wildlife Service's Comments on 

Best Available Retrofit Technology (BART) for PPL Montana's J. E. Corette 

Generating Station (Corette) 

Draft March 12, 2012 

Subsequent to preparing the following comments regarding the BART Determination for the PPL 

Montana J E. Corette Generating Station, the Fish and Wildlife Service has learned of errors in 

the underlying calculations and analysis provided by EPA Region 8. We understand that the 

Agency used bituminous coal parameters in its analysis rather than the Powder River Basin 

(PRE) coal that is combusted at this facility. Our understanding is that correcting this error 

substantially reduces the cost per ton (on the order of15% or more) for several ofthe control 

options discussed. Furthermore, we have identified discrepancies with waste disposal cost 

estimates that resolving couldfurther reduce the resulting control costs. These are outlined in 

the specific sections, below. Additional questions have been raised that have not been addressed 

in this document. 

All data cited below is as it was provided to us March 5, 2012. EPA has indicated that it is 

adjusting its technical support information and spreadsheets to correct the errors. That said, 

our overall conclusions would remain the same, ifnot be strengthened by lower control costs. 

Discussion of SO:z. Controls 

There are at least two other similarly-sized installations implementing lime spray drying (LSD) 

for S02 control that justify the positions taken by Region 8 in the Draft Proposed Best Available 

Retrofit Technology (BART) Determination. In justifying emission limits of small units burning 

clean coal, Newmont Nevada is a 200 MW plant that attains a 30-day rolling average 0.065 

IblMMBtu S02 emission limit with an S02 control efficiency of 93.1 percent. Capital cost of 

LSD units is corroborated by Great River Energy's 188 MW Stanton #1 plant costing 

$79,514,000. 

The capital costs proposed by EPA, Region 8 for dry sorbent injection (DSI) and LSD should be 

considered as maximums, because the costs should only decrease due to significant curtailment 

of construction of air pollution control devices during the economic downturn and cancellation 

or postponement of many coal burning electrical generation units. Quantified estimates of the 

decreases could provide for firm reductions in the capital cost estimates, but it is agreed that they 

would be difficult to affirm with confidence at this time. 

We note discrepancies with the waste disposal cost figures presented in the various spreadsheets. 

In the DSI workbook, waste disposal is quoted at $50/ton, the "IPM default," in row 19 of the "0 

& M Costs" tab, but as $10/ton, citing "Meeting w/ PPL," in row 34 of the "Given/Assume" tab. 

Please clarify the reasons for this 5-fold difference, and explain which estimate EPA is actually 

using in its analysis and the reasons the Agency chose that estimate. In addition, the SDA 

workbook cites waste disposal at $30/ton, the "IPM default for SDA" - while the character of the 

waste stream is likely different, in view ofthe discrepancy noted in the DSI workbook, please 

provide supporting reasoning for the SDA waste disposal rate. Since waste disposal is a 
significant portion of the overall control cost calculation, these items have the potential to affect 

the resulting cost per ton controlled, and cost per deciview improvement. 

The paragraph following Table 123 states that EPA, Region 8 considers $4,659 per ton of S02 

emissions reduction using DSI as reasonable, but that $5,442 per ton for LSD is not cost 

effective. Other proposed S02 BART determinations resulting in cost efficiency in the range of 

Corette include PacifiCorp's Johnston, WY - $4,743; Northshore Mining's Silver Bay Power, 

MN - $7,309 and Xcel Energy's Taconite Harbor, MN - $5,300. As stated above, the capital cost 

of an LSD unit on Great River Energy's 188 MW Stanton #1 plant is $79,514,000. Such a total 

capital cost incorporated as the cost of LSD at Corette would result in a cost per ton of S02 

removed of $4,891. The LSD alternative might then also be considered by EPA, Region 8 as 

being cost effective along with DSI. 

Regarding the cost-effectiveness of visibility improvement for S02 controls, the second 

paragraph after Table 123 in the draft proposed BART determination states, "... the cost of 

controls is not justified by the visibility improvement." This proposed conclusion warrants 

further scrutiny. Implementation of the DSI alternative results in a 0.176 deciview improvement 

at Washakie Wilderness Area, the highest impacted Class I area, at a cost of$3.4 million per 

deciview of improvement. This is a very reasonable cost for visibility improvement. The cost of 

visibility improvement for S02 controls proposed in other BART determinations for a single 

most-impacted Class I area include: 

Colorado Springs Utilities, Martin Drake, CO - $49.9 millionldeciview (dv) 

PacifiCorp, Wyodak, WY - $44.7 millionldv 

PacifiCorp, Jim Bridger, WY - $37.1 millionldv 

PG&E, Boardman, OR - $35.2 millionldv 

Dominion, Brayton Point, MA - $33.9 millionldv 

Northshore Mining, Silver Bay Power, MN - $26.2 millionldv 

Dominion, Salem Harbor, MA - $25.1 millionldv 

Great River Energy, Stanton #1, ND - $21.9 millionldv 

PacifiCorp, Naughton, WY - $18.2 millionldv 

PacifiCorp, Dave Johnson, WY - $16.7 millionldv 

The conclusion from the above is that since the cost per ton ofS02 removal and the cost per 

deciview ofvisibility improvement are both reasonable, DSIshould definitely be considered as a 

feasible and cost-effective S02 control alternative and be accepted as BARTfor the PPL 

Montana, J E. Corette Generating Station. 

In addition, for the three S02 control alternatives, Region 8 made judgments on cost per 

deciview based on only the most impacted Class I area, Washakie Wilderness Area. 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. If 
emissions from Corette are reduced, the benefits will be spread well beyond only the most 

impacted Class I area, and this must be accounted for. 

In this context for the LSD S02 control alternative the cumulative Class I area impact is $12.7 

million per deciview of visibility improvement and as shown above a cost per ton ofS02 

removed of $4,891 could be reasonably construed. This position may cause LSD to be 

considered as being a viable candidate for BARTfor the PPL Montana, J E. Corette Generating 

Station. 

Discussion of NOx Controls 

The discussion regarding NOx control alternatives and a selection of BART will be similar to the 

discussion above for S02 control, since there would seem to be NOx alternatives that are costeffective in terms of cost per ton ofNOx reduced as well as cost per deciview of visibility 

improvement. In the draft proposed BART determination the paragraph after Table 109 states 

that no new BART controls will be added. The paragraph after Table 110 states that all three 

NOx control alternatives are cost-effective, but the second paragraph after Table 110 states that 

the cost of controls is not justified by the visibility improvement. 

Table 110 states the visibility improvement associated with each of the three NOx control 

alternatives. By dividing respective Total Annual Costs by their visibility improvements, they 

result in cost per deciview of visibility improvement from $16.7 million to $17.8 million at the 

Washakie Wilderness Area, the highest impacted Class I area. When these values are compared 

to the single Class I area impacts for some other NOx BART proposals as summarized below, it 

would indicate that they each could be considered as reasonable: 

Great River Energy, Stanton #1, ND - $41.0 millionldeciview (dv). 

Arizona Public Service, Navajo Nation, AZ - $39.9 millionldv 

Xcel Energy, Sherburne County Generating Station, MN - $33.1 millionldv 

Nevada Energy, Ft. Churchill, NY - $27.4 millionldv 

PacifiCorp, Laramie River, WY - $27.4 millionldv 

Basin Electric, Leland Olds, ND - $27.2 millionldv 

PacifiCorp, Naughton, WY - $22.8 millionldv 

PacifiCorp, Jim Bridger, WY - $18.5 millionldv 

Minnkota, Power M R Young, ND - $16.1 millionldv 

When Total Annual Cost for each ofthe three NOx control alternatives is divided by the 

respective visibility improvement for all affected Class I areas (as discussed above for S02) they 

result in cost per deciview of visibility improvement from $4.7 million to $5.0 million, which is 

a very reasonable visibility cost. 

The conclusion from the above is that since the cost per ton ofNOx removal and the cost per 

deciview ofvisibility improvement are both reasonable, at least the Separated Over-fire Air 

(SOFA)-only or, preferably SOFA plus Selective Non-Catalytic Reduction (SNCR) should 

definitely be considered as feasible and cost-effective NOx control alternatives and be accepted 

as BARTfor the PPL Montana, J E. Corette Generating Station. 
On page 36 of the draft proposed BART determination regarding BART-eligible sources, the 2

Dd 

and 4th paragraphs of narrative do not include Corette, but then Corette does appear as item 7 in 

both Table 8 and Table 9. It is unclear why Corette was not included in the narrative, but was 

rightfully included in the tables.