IN REPLY REFER TO: 

N3615 (2350) 

September 4, 2012 

Pamela Blakley, Chief 

Control Strategies Section 

United States Department of the Interior 

NATIONAL PARK SERVICE 

Air Resources Division 

P.O. Box 25287 

Denver, Colorado 80225 

Air Programs Branch (AR-18J) 

U.S. Environmental Protection Agency Region 5 

77 West Jackson Boulevard 

Chicago, lllinois 60604 

EPA Docket ID: EPA-R05-0AR-2010-0954 

Dear Ms. Blakley: 

The National Park Service (NPS) has reviewed the Environmental Protection Agency's (EPA's) 

proposed "Approval and Promulgation of Air Quality hnplementation Plans; Michigan; Regional 

Haze State Implementation Plan; Federal Implementation Plan for Regional Haze". We 

generally commend EPA's proposals for Best Available Retrofit Technology (BART) for four 

industrial sources (comments enclosed), and have brief comments on BART for electric utilities 

and reasonable progress goals, as detailed below. 

On June 7, 2012, EPA disapproved Michigan's regional haze plan (and those of several other 

states) due to reliance on the Clean Air Interstate Rule (CAIR) to meet BART requirements for 

electric utilities. In the same decision, EPA determined that emissions reductions under the 

Cross State Air Pollution Rule (CSAPR) achieve greater progress in improving visibility than 

source-specific controls for BART and promulgated Federal hnplementation Plans that relied on 

CSAPR to meet BART requirements for electric utilities in Michigan (and other states). On 

August 21, 2012, the U.S. Court of Appeals for the District of Columbia Circuit vacated the 

CSAPR, temporarily leaving CAIR . Because EPA previously disapproved the state plans that 

relied on CAIR to meet BART, it appears that EPA carmot finalize the proposed approval of 

BART for electric utilities in Michigan. To finalize the regional haze plan, we recommend that 

Michigan evaluate BART for those electric utilities subject BART. 

We believe that consistent application of the regional haze rule requirements across states and 

EPA regions is important. 40 CFR 51.308 (d) (1) requires states to establish goals that provide 
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for an improvement in visibility for the most impaired days and ensure no degradation in 

visibility for the least impaired days. We are concerned that EPA did not consider the projected 

degradation of visibility on the least impaired days when proposing to approve Michigan's 

reasonable progress goals. The regional air quality model used by Michigan projects that 

visibility on the 20% best days at Seney Wildlife Refuge will be poorer in 2018 (7.78 deciview) 

than in the 2000-2004 baseline period (7.14 deciview). EPA should discuss this finding and why 

Michigan's reasonable progress goals are acceptable despite failing to meet a fundamental rule 

requirement. 

We appreciate the opportunity to work closely with Michigan and EPA Region 5 to make 

progress toward achieving natural visibility conditions at our National Parks and Wilderness 

Areas. For further information regarding our comments, please contact Pat Brewer at (303) 969-

2153. 

Sincerely, 

Susan Johnson 

Chief, Policy, Planning and Permit Review Branch 

Enclosure 

cc: 

Vinson Hellwig, Chief 

Air Quality Division 

Michigan Department of Natural Resources and Environment 

525 West Allegan Street, P.O. Box 30473 

Lansing, Michigan 48909-7973 
National Park Service Comments on EPA's Proposals for 

Best Available Retrofit Technology (BART) for St. Mary's Cement and NewPage Paper 

September 4, 2012 

St. Mary's Cement 

We commend EPA's treatment of St. Mary's Cement as a BART source, for the reasons detailed 

here. We agree with EPA that Selective Non-Catalytic Reduction (SNCR) technology is feasible 

for St. Mary's Cement and can be successfully operated at reasonable cost at this plant. Our 

review of BART proposals for cement plants across the US has found that SNCR has been 

determined to be technically feasible in every case (although Pennsylvania rejected SNCR on the 

basis of excessive cost!dv of improvement at the most-impacted Class I area). 

SNCR SNCRCost 

BART Reducti 

Company State Unit Kiln Type on% $/ton $/dv BART 

Essroc Cement PA Kiln#5 long, wet 35% $ 1,014 $ 7,494,026 Seasonal NOx controls 

Lehigh Cement/York PA white cement 35% $ 1,505 $ 10,606,000 Seasonal NOx controls 

Lehigh Cement 

Company/Evansville PA Kiln#! dry preheater 60% $ 627 $ 8,094,250 Seasonal NOx controls 

Lehigh Cement 

Company/Evansville PA Kiln#2 dry preheater 60% $ 627 $ 8,094,250 Seasonal NOx controls 

Lafarge 

Corporation/Whitehall PA Kiln#2 drv oreheater 25% $ 1,804 $ 27,177,065 Seasonal NOx controls 

Lafarge 

Corporation/Whitehall PA Kiln #3 dry preheater 25% $ 2,144 $ 24,336,753 Seasonal NOx controls 

Cemex!Wamoum PA Kihl #3 long, drv kiln 35% $ 1,014 $ 4,678,401 Seasonal NOx controls 

Keystone Cement PA Kiln#2 Iom1:, wet kiln 35% $ 1,014 $ 23,431,248 Seasonal NOx controls 

Ash Grove Cement MT long, wet kiln 58% $ 2,058 $ 1,793,984 LNB&SNCR 

CEMEX co preheater/precalciner 48% $ 1,934 $ 4,306,937 SNCR 

Holcim Cement co preheater/precalciner 45% $ 2,293 $ 8,750,000 SNCR 

Holcim Cement MT long, wet kiln 58% $ 1,528 $ 2,325,106 SNCR 

LaFarge North America Kiln long, dry process 

(cement) MI #19 kilns 35% $ 731 SNCR 

LaFarge North America Kiln long, dry process 

(cement) Ml #20 kilns 35% $ 731 SNCR 

LaFarge North America Kiln long, dry process 

(cement) Ml #21 kilns 35% $ 731 SNCR 

LaFarge North America Kiln long, dry process 

(cement) Ml #22 kilns 40% $ 498 SNCR 

LaFarge North America Kiln long, dry process 

(cement) Ml #23 kilns 40% $ 498 SNCR 

St. Marv's Cement Ml preheater/precalciner 50% $ 983 $ 3,084,550 EPASNCR 

LaFarge North America SNCR or mid-kiln 

(cement) WA wet orocess kiln 40% $ 4,190 $ 1,758,980 firing of whole tires 

We also note that SNCR was considered to be technically feasible at three kilns at Dacotah 

Cement in South Dakota evaluated under the Reasonable progress provisions of the Regional 

Haze Rule. 

We support EPA's proposal that the appropriate limit for NOx emissions from the kiln at St. 

Mary's Cement would reflect a 50 percent reduction from the average emissions, which falls 

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within the range of emission reductions we have seen assumed for SNCR. We agree with EPA's 

proposal to establish a limit on NOx emissions at 2.30 pounds per ton of clinker (30 - day rolling 

average). 

We also support EPA's proposed limit for S02 emissions per ton of clinker to assure that 

emissions do not increase significantly above current levels. EPA is proposing to set a limit that 

reflects a 5 percent compliance margin relative to the average S02 emission rate at this facility 

Based on CEMS data for 2006 to 2008; that is, a limit of 7.5 pounds of S02 emissions per ton of 

clinker as a 30-day rolling average. We commend EPA for basing its proposal upon actual 

emissions data and concur with the proposed limit. 

We commend EPA for requiring that BART controls be installed and operated as expeditiously 

as practicable, consistent with 40 CFR 51.308(e)(1)(iv). EPA believes that Saint Mary's Cement 

may reasonably be required to conduct the engineering, design, installation, and trial operation of 

the SNCR to meet this limit within about three years from the expected effective date of final 

promulgation of these limits. Therefore, EPA is proposing a compliance date for the NOx limit 

ofJanuary 1, 2016. EPA is proposing that the S02 limit apply upon the effective date of the final 

promulgation of the limit, because the company is already complying with the limit. EPA 

envisions using data from the existing continuous emission monitoring system that measures 

NOx and S02 emissions from the kiln to evaluate compliance with the NOx and S02 limits it is 

proposing. 

NewPage Paper 

NewPage Paper owns and operates a paper mill in Escanaba, Michigan. EPA's review focused 

on the largest of the BART sources at the facility, Boiler 8 and Boiler 9. 1 Boiler 8 is permitted to 

burn both natural gas and residual oil, but has only burned natural gas in recent years. Because 

NewPage's 2007 BART report estimates a 0.2 dv improvement due to switching from #6 

residual oil to natural gas, we recommend that EPA re-evaluate BART for S02 as eliminating 

residual oil as a fuel option for Boiler 8.2 

For NOx, we agree with EPA's proposal of fuel-specific limits of 0.26lb/mmBtu for combustion 

of natural gas and 0.50 lb/mmBtu for combustion of residual oil, if residual oil is not eliminated 

as a fuel option. These limits are approximately 10 percent above the upper end of the range of 

emission rates under current operation. 3 EPA envisions that the company will be able to meet 

1 Michigan identified several other units at NewPage Paper that are subject to a requirement for BART, including 

the Number lO recovery furnace, a lime kiln, and the smelt dissolving tank. EPA concurs with Michigan's 

conclusion that these other units do not require limits to require BART controls. 

2 Boiler 8 is permitted to burn #6 residual oil with a sulfur content of 1.0% and has a 98th percentile impact of 0.4 dv. 

Table 2-6 of NewPage's 2007 BART report estimates that switching to natural gas would reduce 98th percentile 

impacts from this boiler by 0.2 dv. Table C-5 of that report estimates that switching to natural gas would have a 

cost-effectiveness of $4,222/ton based upon 2006 costs of $6.84/mmBtu for 0.57%S #6 fuel oil and $8.05/mmBtu 

for natural gas. At current natural gas prices, the cost-effectiveness of switching to natural gas would be less than 

$1 ,500/ton. 

3 Compliance information will be obtained from a continuous emission monitoring system that the company 

operates on this boiler. Since the boiler is often not operating, EPA will compute 30-day averages on the basis of 30 

successive operating days, not counting days in which the boiler does not operate. 

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these limits by maintaining existing operations (maintaining existing combustion improvements), 

but finds that the company also has the flexibility to meet these limits by installing low-NOx 

burners or using its flue gas recirculation equipment more frequently. We agree with EPA's 

conclusion that these limits are warranted as BART but that further emission reductions are not 

warranted for the limited benefits they would achieve. 

For Boiler 9 we agree with EPA's conclusion that the overfire air modifications that the 

company has made are included in BART for this boiler and that no further control of this boiler 

constitutes BART. We agree with EPA's proposed limits to mandate the continued operation of 

the existing overfire air system on Boiler 9. 

However, no system for continuous emission monitoring is operating on this boiler and EPA is 

proposing a limit that would be enforced by stack tests. To accommodate a modest degree of 

stack test variability, EPA is proposing to set a limit with a 25 percent compliance margin. That 

is, EPA is proposing a NOx emission limit for Boiler 9 of 0.27 lb/mmBtu. (This emission rate 

also is about 10 percent higher than the highest single run test result reported by the company.) 

We have two concerns with EPA's proposal: 

• Stack testing is not necessarily representative of day-to-day emissions and a boiler with 

emissions of this magnitude should be equipped with NOx CEMs. (After all, Boiler 8 has 

one-sixth the annual NOx emissions of Boiler 9 and is required to operate NOx CEMs.) 

We recommend installation and operation of NOx CEMs to allow an appropriate NOx 

limit to be set on the 30-day rolling average basis (or on a 30 boiler-operating-day basis 

as proposed for Boiler 8), which would be consistent with most BART limits. 

• Because of its proposal to rely upon stack testing with its inherent variability, EPA has 

had to allow a 25 percent "compliance margin" instead of the lower compliance margin 

proposed for Boiler 8. If the stack test results cited by EPA are truly representative, then 

we recommend that a 30-day rolling average of 0.24 lb/mmBtu (20 percent above the 

lower value and 10 percent above the higher value) would be more appropriate. 

NewPage Paper has already implemented measures to meet the limits on Boilers 8 and 9. 

Therefore, we agree with EPA's proposal that the final limits take effect upon the effective date 

of the rulemaking promulgating these limits. 

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