IN REPLY REFERTO:

N3615 (2350)
September 4, 2012

Pamela Blakley, Chief Control Strategies Section 

### United StatesDepartmentofthe Interior NATIONAL PARK SERVICE AirResources Division P.O. Box 25287 Denver, Colorado 80225

Air Programs Branch (AR-18J) U.S. Environmental ProtectionAgency Region 

### 5 77 WestJackson Boulevard Chicago, lllinois 60604 EPADocket 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 ofAir Quality hnplementationPlans; Michigan; Regional Haze State Implementation Plan; Federal ImplementationPlanfor Regional Haze". We generally commend EPA's proposals for BestAvailable RetrofitTechnology (BART) for four industrial sources (comments enclosed), and havebriefcomments on BART for electric utilities and reasonable progress goals, as detailed below. OnJune 7, 2012, EPA disapproved Michigan's regional haze plan (and those ofseveral other states) due to reliance on the CleanAir Interstate Rule (CAIR) to meetBARTrequirements for electric utilities. In the same decision, EPA determined that emissions reductions under the Cross State Air PollutionRule (CSAPR) achieve greater progress in improving visibilitythan 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 ofAppeals for the District ofColumbia 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 inMichigan. To finalize the regional haze plan, we recommend that Michigan evaluate BART for those electricutilities subject BART. Webelieve that consistent application ofthe regional haze rule requirements across states and EPA regions is important. 40 CFR 51.308 (d) (1) requires states to establish goals that provide2

for an improvement in visibility for the most impaired days and ensure no degradation in visibilityfor the least impaired days. We are concerned thatEPA did not consider the projected degradation ofvisibility on the least impaired days whenproposing to approve Michigan's reasonable progress goals. The regional air quality model used by Michigan projects that visibility on the 20% best days at SeneyWildlife Refuge will bepoorer in 2018 (7.78 deciview) than in the 2000-2004 baselineperiod (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. Forfurther 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 ofNatural Resources and Environment 525 WestAllegan Street, P.O. Box 30473 Lansing, Michigan 48909-7973National Park Service Comments onEPA's Proposals for BestAvailable Retrofit Technology (BART) for St. Mary's Cement and NewPage Paper September4, 2012

St. Mary's Cement We commend EPA's treatment ofSt. Mary's Cement as a BART source, for the reasons detailed here. We agree with EPAthat Selective Non-Catalytic Reduction (SNCR) technology is feasible for St. Mary's Cement and canbe successfully operated at reasonable cost at this plant. Our review ofBART proposals for cementplants across the US has found that SNCRhas been determined to be technically feasible inevery case (although Pennsylvaniarejected SNCR onthe basis ofexcessive cost!dv ofimprovement at the most-impactedClass 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:, wetkiln 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 ofwhole 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 ofthe Regional Haze Rule. We supportEPA'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


### 1within therange ofemissionreductions wehave seen assumed for SNCR. We agree with EPA's proposal to establish a limit on NOx emissions at 2.30 pounds per tonofclinker (30

- day rolling average).
We also supportEPA's proposed limit for S02emissions pertonofclinker to assure that emissions do not increase significantly above current levels. EPA is proposing to set a limit that reflects a 5 percent compliance marginrelative to the average S02emissionrate at this facility Based onCEMS data for 2006 to 2008; that is, a limit of7.5 pounds ofS02 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 commendEPA for requiring that BART controls be installed and operated as expeditiously as practicable, consistentwith 40 CFR 51.308(e)(1)(iv). EPAbelieves that Saint Mary's Cement mayreasonably berequired to conductthe engineering, design, installation, and trial operation of the SNCR to meet this limit within about three years from the expected effective date offinal promulgation ofthese limits. Therefore, EPA is proposing a compliance date for the NOx limit ofJanuary 1, 2016. EPA is proposing that the S02limit apply upon the effective date ofthe final promulgation ofthe limit, becausethe 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 thekilnto evaluate compliance with the NOx and S02limits it is proposing. NewPage Paper NewPage Paperowns and operates a papermill in Escanaba, Michigan. EPA's review focused onthe largest ofthe BART sources at the facility, Boiler 8 and Boiler 9. 1 Boiler 8 is permitted to burnbothnatural gas and residual oil, buthas onlyburned natural gas inrecent years. Because NewPage's 2007 BARTreport estimates a 0.2 dv improvement due to switching from #6 residual oil to natural gas, werecommend that EPAre-evaluate BARTfor S02as eliminating residual oil as a fuel option for Boiler 8.2
ForNOx, we agree with EPA's proposal offuel-specific limits of0.26lb/mmBtufor combustion ofnatural gas and 0.50 lb/mmBtu for combustion ofresidual oil, ifresidual oil is not eliminated as a fuel option. These limits are approximately 10 percent above the upper end ofthe range of emissionrates under current operation.3 EPA envisions that the company will be able to meet

1 Michigan identified several other units at NewPagePaper 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 notrequire limits to require BARTcontrols.

2 Boiler 8 is permitted to burn#6 residual oil with a sulfur content of 1.0% and has a 98th percentile impact of0.4 dv. Table 2-6 ofNewPage'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 ofthat report estimates that switching to natural gas would have a cost-effectiveness of$4,222/tonbased 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. 2these limits by maintaining existing operations (maintaining existing combustion improvements), butfinds that the company also has the flexibility to meetthese limits by installing low-NOx burners or using its flue gas recirculation equipment more frequently. We agree with EPA's conclusionthat these limits are warranted as BARTbutthat 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 companyhas made are included in BART for this boiler and thatno further control ofthis 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 onthis boiler and EPA is proposing a limit that wouldbe enforcedby 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 of0.27 lb/mmBtu. (This emissionrate also is about 10 percenthigher than the highest single run test resultreported by the company.) Wehavetwo concerns with EPA's proposal:

• Stacktesting is not necessarily representative ofday-to-day emissions and a boiler with emissions ofthis magnitude shouldbe equipped with NOx CEMs. (After all, Boiler 8has one-sixththe annual NOx emissions ofBoiler9 and is required to operate NOx CEMs.) We recommend installation and operation ofNOx CEMs to allow an appropriate NOx limitto be set onthe 30-dayrolling average basis (or on a30boiler-operating-daybasis as proposed for Boiler 8), which wouldbe consistent with most BART limits. • Because ofits proposal to rely upon stacktesting with its inherent variability, EPAhas had to allow a 25 percent "compliance margin" instead ofthe lower compliance margin proposedfor Boiler 8. Ifthe stack test results citedbyEPA are truly representative, then we recommend that a 30-dayrolling average of0.24 lb/mmBtu (20 percent above the lower value and 10 percent above the higher value) would be more appropriate. NewPage Paperhas already implemented measures to meetthe limits onBoilers 8 and 9. Therefore, we agree with EPA's proposal that the final limits take effect upon the effective date ofthe rulemaking promulgating these limits.



### 3