# United States Department ofthe Interior
ASHAND WILDLIFE SERVICE National Wildlife Refuge System Branch ofAir 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 QualityPlanning Unit AirProgram 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 ofthe Regional Haze Federal Implementation Plan for the State ofMontana. The U.S. Fish and Wildlife Service (FWS) and National Park Service (NPS) appreciate the opportunityto 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 ofhighlighted 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 ofBest Available Retrofit Technology and reasonable progress that support which emissions controls are cost effective and what level ofvisibility improvement is necessary tojustify emission control costs. While our enclosed comments address your analysis ofCorette 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 thebasis ofthe 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 ofEnvironmental Quality 1520 E. Sixth Avenue P.O. Box 200901 Helena, MT 59620-0901Comments 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 thevery short review time available, we are focusing ourinitial comments on a limited number ofhighlighted items. We intend to continue ourcollaborative 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 thecontext 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 ofsource specific BART and source specific reasonable progress analyses. We suggest moving the first three sections ofsection D: LongTerm Strategies, to become section C: Emissions Inventory and section D: Sources ofVisibility 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 onpoint source emissions ofsulfur 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 byless than 1percentby 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 capacityby 2018. Please clarify ifthe projected new facilities are still expected by 2018. Ifnot, please clarify that S02 emissions will be reduced more than reported in Table 140. Onpage 166, supportingTable 141, EPA explains that the WRAP assumed 23,000 tons ofNOx would bereduced at Colstrip by 2018 due to an enforcement action and additional controls required bythe Regional Haze FIP. Please add an explanation what fraction ofthe 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 ofrapid change with large areas ofsignificant growth. This growth has considerable cumulative impact potential to visibility at Class I areas across Montana and at nearby States. The emission inventoryutilized byWRAP is severely out ofdate for this sector and does not represent the full impactpotential. We ask that additional discussion be included in the FIP proposal addressing this activity. We also request that this issuebe identified as one that will be addressed as part ofthe upcoming five yearreview. 

### Best Available Retrofit Technology (BART) We request clarification on the criteria used to determine what costs or visibilitybenefits 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 ofStates, in establishing their control decisions for BART or RP, have identified consistent criteria for source controls. Thedraft 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 bejustified by the visibility improvement even though the $/dv cost effectiveness was lower than for controls that arebeingrequired. Since some ofthe review materials are still outstanding, we understand that we maynot have the full description ofcontrol evaluation at this time. We request your assistance in clarifying this issue. Cumulative visibilitybenefits at multiple Class I areas should be considered when evaluating cost effectiveness ofcontrol options. EPA presented visibilitybenefits for all Class I areas in the BART analyses, but compared costs to maximum visibilitybenefit 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 PPLMontana J. E. Corette Generating Station. The confoundingfactors ofa relatively smallerunit size (162 megawatt 

## (MW» and very low-sulfur coal (Powder River Basin (PRB) 0.3% sulfur content/uncontrolled emission rate of0.46 Ibs/MMBtu) constrain the cost-efficiency ofcontrol 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 ofBARTdeterminations in the cost range ofcontrols for Corette. 

### Columbia Falls Aluminum Company We request that EPA strengthenthe discussion ofthe BARTrequirements for ColumbiaFalls in the FIP proposal and provide notice to the companythat ifthe facility were to restart, a BART analysis would berequired. 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. ColumbiaFalls is only 10 km from GlacierNational Park, and preliminaryWRAP 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 bepart ofits planningprocess. The current text is not clear whether the source would berequired to perform BART before or after restarting.

2

### Reasonable Progress Analyses EPA identified point source emissions ofS02 and NOx as the most important sector to consider for reasonable progress, and yet required onlyDevon Energy to reduce emissions. EPA determined that costs are excessive for all sources except DevonEnergy, yet the costs that were determined to be excessive are lowerthan costs determined to be reasonable for BART sources. Please explain. Forthe 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 proposingreasonable progress goals for the 20% worst visibility days for the Montana Class I areas that are significantly less than (16-51%) the uniform rate ofprogress (page 284). EPA needs to pay careful attention to the precedent setbyjustifying the proposed reasonable progress goals. EPA cites the contribution ofnatural 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 BARTreductions 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 statethat the emissions reductions under EPA's proposal are greater than the reductions modeled bythe 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 commitmentto the other WRAP states. Itis not likely that the actual rate ofprogress will be significantly closer to the uniform rate of progress than the WRAP modelingprojections, as EPA states onpage 287. Several western states have used separate glide paths for each visibility impairingpollutant as added weight ofevidence to demonstrate that the state is makingreasonable progress on the pollutants that are controllable bythe states. In the case ofMontana, 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 ofMontana Class I areas. Wewould like to discuss this further with EPA. 

### Additional information on the Montana Smoke ManagementPlan (SMP) Accordingto the draft FIP, the State submitted an updated version ofits SMP on February 17, 2012. Although not available for review, we are encouraged bythe commitment to consider visibility impacts when, "developing, issuing or conditioningpermits and making dispersion forecast recommendations." However, it is not clear whetherthe SMP incorporates best management practices (BMPs), emission tracking, or enhanced practices to minimize impacts, as discussed bythe 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 connectingthe SMP to theregional haze FIP. Werequest that you include statements to the proposal indicating whether the SMP addresses these additional attributes.

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# - ..---­**~0--l** --------.------ -------. ---==....::::­ Consultation EPA was not able to provide Federal Land Managers sixty days review. We received and reviewed PIP materials within the pastthree 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.

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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 topreparing thefollowing comments regarding the BARTDetermination for the PPL Montana J E. Corette GeneratingStation, the Fish and Wildlife Service has learned oferrors in the underlying calculations andanalysisprovidedbyEPA Region 8. We understandthat the Agency usedbituminous coalparameters in its analysis rather than the PowderRiverBasin (PRE) coal that is combustedat this facility. Our understanding is that correcting this error substantially reduces the costper ton (on the order of

### 15% or more) for several of the control options discussed. Furthermore, we have identifieddiscrepancies with waste disposal cost estimates that resolving could further reduce the resulting control costs. These are outlinedin the specific sections, below. Additionalquestions have been raised that have not been addressed in this document. Alldata citedbelow is as itwasprovided to us March 

### 5, 2012. EPA has indicated that it is adjusting its technicalsupport information andspreadsheets to correct the errors. That said, our overallconclusions would remain the same, if not be strengthenedby lower control costs.

Discussion ofSO:z. Controls There are at least two other similarly-sized installations implementing lime spray drying (LSD) for S02 control thatjustifythe positions taken byRegion 8 in the Draft Proposed Best Available Retrofit Technology (BART) Determination. 

### Injustifying emission limits ofsmall units burning clean coal, Newmont Nevada is a 200 MWplant that attains a 30-day rolling average 0.065 IblMMBtu S02 emission limit with an S02 control efficiency of93.1 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 byEPA, Region 8 for dry sorbent injection (DSI) and LSD should be considered as maximums, because the costs should onlydecrease due to significant curtailment ofconstruction ofair pollution control devices during the economic downturn and cancellation orpostponement ofmany coal burning electrical generation units. Quantified estimates ofthe 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 ofthe "0 & M Costs" tab, but as $10/ton, citing "Meeting w/ PPL," in row 34 ofthe "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 ofthe 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 asignificant portion ofthe overall control cost calculation, these items have the potential to affect theresulting cost perton controlled, and cost per deciview improvement. Theparagraph following Table 123 states that EPA, Region 8 considers $4,659 perton ofS02 emissions reduction using DSI as reasonable, but that $5,442 perton for LSD is not cost effective. Otherproposed 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 ofan 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 ofLSD at Corette would result in a cost perton ofS02 removed of$4,891. The LSD alternative might then also be considered byEPA, Region 8 as being cost effective along with DSI. Regarding the cost-effectiveness ofvisibility improvement for S02 controls, the second paragraph after Table 123 in the draftproposed BART determination states, "

... the cost of controls is notjustified by the visibility improvement." This proposed conclusion warrants further scrutiny. Implementation ofthe DSI alternative results in a 0.176 deciview improvement at Washakie Wilderness Area, the highest impacted Class I area, at a cost of$3.4million per deciview ofimprovement. 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, SilverBay 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 conclusionfrom the above is that since the costper ton ofS02 removal and the costper deciview of visibility improvement are both reasonable, DSIshoulddefinitely be consideredas a feasible andcost-effective S02 control alternative andbe accepted as BART for the PPL Montana, J E. Corette Generating Station. In addition, for the three S02 control alternatives, Region 8 madejudgments 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 considerboth the degree ofvisibility improvement in a given Class I area as well as the cumulative effects ofimproving visibility across all ofthe Class I areas affected. It simply does not make sense to use the same metric to evaluate the effects ofreducing 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. Ifemissions from Corette are reduced, the benefits will be spread well beyond only the most impacted Class I area, and this mustbe accounted for. In this context for the LSD S02 control alternative the cumulative Class I area impact is $12.7 million per deciview ofvisibility improvement and as shown above a cost perton ofS02 removed of$4,891 could bereasonably construed. Thisposition may causeLSD to be consideredas beinga viable candidate for BART for the PPL Montana, J E. Corette Generating Station. Discussion of NOx Controls The discussion regarding NOx control alternatives and a selection ofBART will be similarto the discussion above for S02 control, since there would seem to beNOx alternatives that are costeffective in terms ofcost per ton ofNOx reduced as well as cost per deciview ofvisibility improvement. In the draft proposed BART determination the paragraph after Table 109 states that no new BART controls will be added. Theparagraph after Table 110 states that all three NOx control alternatives are cost-effective, but the second paragraph after Table 110 states that the cost ofcontrols is notjustifiedby the visibility improvement. Table 110 states the visibility improvement associated with each ofthe three NOx control alternatives. By dividing respective Total Annual Costs by theirvisibility improvements, they result in costper deciview ofvisibility 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 BasinElectric, 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 perdeciview ofvisibility 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 costper ton of NOx removal andthe costper deciview of visibility improvement are both reasonable, at least the Separated Over-fireAir (SOFA)-only or, preferablySOFAplus Selective Non-Catalytic Reduction (SNCR) should definitely be consideredasfeasible and cost-effective NOx control alternatives and be accepted as BART for the PPLMontana, J E. Corette GeneratingStation.On page 36 ofthe draft proposed BART determination regarding BART-eligible sources, the 2Dd and 4th paragraphs ofnarrative 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.