UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 5 

AIR AND RADIATION DIVISION 

77 WEST JACKSON BOULEVARD 

CHICAGO, IL 60604-3590 

REPLY TO THE ATTENTION OF: 

Lorraine Hickman 

Air Quality Division 

JUN Z 3 2010 

Michigan Department ofNatural Resources and Environment 

P.O. Box 30260 

Lansing, Michigan 48909 

Dear Ms. Hickman: 

A-18J 

We appreciate Michigan's work in preparing and drafting a regional haze SIP submittal. 

Enclosed are our comments on this draft submittal. We welcome any discussions of these 

comments that would be helpful to you, and we look forward to receipt of a final submittal that 

addresses these comments. 

The Forest Service has also sent you comments, dated June 21,2010. We share their concerns, 

particularly regarding the determinations that existing controls satisfY the requirement for best 

available retrofit technology for three of the four sources subject to this requirement. Your 

response to these comments will be an important factor in our evaluation of your prospective 

submittal. 

Thank you again for your work in addressing regional haze. Please contact John Summerhays at 

312-886-6067 or Steve Rosenthal at 312-886-6052 if you have any questions. 

Sincerely, 

Michael Compher, Acting Chief 

Attainment Planning and Maintenance Section 

Enclosure 
Comments on Draft Michigan Regional Haze Plan 

Comments on Best Available Retrofit Technology (BART)

Michigan’s submittal should provide that the shut down of Empire Mine's furnace is permanent. 

St. Mary's Cement (SMC) BART Comments

We disagree with MDEQ's assessment that a selective non-catalytic reduction system is 

technically infeasible and not cost-effective. There does not appear to be documentation 

describing why SMC has insurmountable problems operating a SNCR system in winter. Also, 

four other cement plants are proposing SNCR as BART. These are Ash Grove Cement in 

Montana, CEMEX in Colorado, Holcim Cement in Montana, and LaFarge North America in 

Washington. The average cost effectiveness range of $900-1200 per ton, as reported in the 

MANE-VU document regarding SNCR, further suggests the cost effectiveness of SNCR. In 

addition, the 10 percent control efficiency that SMC assumed for SNCR appears too low. The 

Lafarge BART analysis, for example, states the "expected control effectiveness of SNCR (on the 

order of 30 to 40 percent based on publicly available data)." 

New Page (NP) - Escanaba BART Comments

There is no basis for rejecting control options for the boilers because "visibility modeling does 

not indicate it will result in a significant visibility improvement (i.e., at least 0.5 deciviews)." 

The BART guidelines provide no such basis for rejecting control options. 

If the interest rate and expected equipment life for the low NOx burner (LNB) analysis for Boiler 

No. 8 is made consistent with other analyses (15 years and 7% versus 10 years and 10%), along 

with eliminating the costs associated with apparently unnecessary labor, the average cost 

effectiveness is $2100 per ton. The SNCR BART analysis for Boiler No.9 is extremely 

inconsistent with the MANE-VU document costs. An explanation should be provided for this 

extremely large discrepancy. As stated for Boiler No. 8, the expected equipment life of 10 years 

and interest rate of 10% should probably be 15 years and 7%. 

Tilden Mining Company (TMC)

It should be noted that in April, USS Minntac installed a low-NOx main burner firing solid fuels 

in its furnace and extensive work done by a number of companies in Minnesota has shown that 

burner designs that lower the flame temperature can reduce NOx formation in taconite furnaces. 

Low-NOx burners are also being designed for a new taconite plant, Essar Steel, that will fire 

natural gas. Also, in a separate permitting action, the Minnesota Pollution Control Agency 

(MPCA) has determined that LoTOx is technically and economically feasible for a different 

taconite facility. 

Regarding sulfur dioxide, the MPCA has determined that the addition of a scrubber at the United 

Taconite plant that burns primarily coal was technically and economically feasible. To arrive at 
this conclusion the MPCA corrected the cost analysis submitted by the same consultant who 

submitted Tilden's BART analysis. 

As the only taconite plants in the US are located in Minnesota and Michigan, Michigan should 

be consistent with what Minnesota has done, especially the requirement to install NOx and SO2 

CEMs and perform a pilot testing program of potential NOx control strategies starting in July 

2011. 

Tilden's revised BART scenario, which shows that SO2 alone does not cause visibility 

impairment to Class 1 areas, is inconsistent with EPA policy and is therefore not an adequate 

basis for concluding that the current Title V permit limits for SO2 emissions of 28,800 lbs per 

day should be considered BART. 

Other Comments

1. Given the regional nature of regional haze, we consider Michigan’s test for significance, 

based on whether a state contributes 5 percent of the regional haze, to be an overly stringent test 

that indicates too few significant contributors. Although EPA does not specify a particular test 

of significance for states to use, the alternative contemplated by Michigan, based on whether a 

state contributes 2 percent of the regional haze, likely provides a better indicator of whether a 

state has a contribution that warrants addressing. 

2. We would not agree that the Midwest Regional Planning Organization is dormant. In any 

case, we would note that the Lake Michigan Air Directors Consortium continues to perform 

work on regional haze and other related air pollution issues, currently based primarily on state 

funding. 

3. The discussion of factors to be considered in defining BART lists instead the statutory factors 

for evaluating reasonable progress. The Clean Air Act has a set of five factors for BART that 

differ somewhat from the four factors listed on page 7. 

4. Although the regional haze rule provides for CAIR where applicable to satisfy the BART 

requirement with respect to SO2 and NOx from electric generating units, EPA is reconsidering 

this guidance. Therefore, we would not necessarily agree that it is “EPA’s position” that CAIR 

satisfies pertinent BART requirements. Similarly, Michigan should avoid statements as to 

whether EPA does or doesn’t intend for CAIR to “address reasonable controls for [electric 

generating units] in . . . regional haze SIPs.” 

5. The reasonable progress goals are based on modeling runs that do not reflect BART 

determinations in Michigan and other states. While future haze levels are difficult to predict, 

especially due to uncertainties regarding utility control requirements and control levels, EPA will 
expect Michigan to establish reasonable progress goals that reflect at least an approximation of 

BART control levels. 

6. Michigan must submit the documents that are to provide for federal enforceability of specific 

limits representing BART. Even if these limits are already federally enforceable, Michigan must 

submit these documents for inclusion in the docket for EPA’s rulemaking on Michigan’s 

prospective SIP submittal and for incorporation by reference as part of Michigan’s SIP. 

7. The consent decree that Michigan is relying on to require BART level controls specifies 

interim emission limits but also provides for testing to determine final emission limits. When 

final limits are determined, the consent decree will be replaced by a permit that Michigan is 

expected to issue. Although the interim limit may suffice for current haze SIP purposes, 

Michigan needs to describe how it will process the final limits. In particular, Michigan needs to 

describe how it intends for the ultimate limit to become enforceable by the State and by EPA and 

how it will become part of the SIP, so as to replace the consent decree before the consent decree 

expires. If Michigan intends to rely on a Title V permit to provide for federal enforceability of 

the replacing limits, Michigan will need to address questions about whether it has authority to 

define a BART limit in a Title V permit rather than having the Title V permit simply compile a 

limit established elsewhere. As a general matter, Title V permits do not offer a proper 

mechanism for setting new limits.