### 1 

## A. **Analysis of 309 (g)**  **Comments Received in Response to the November 18**  **, 200 3**  **Public Hearing**

The Division responded to comments following each public comment period with responses that were relevant during that time pe riod. No attempt was made to revise responses from earlier time periods. As information changed over time, the Division’s responses changed accordingly.

Commenter Comment # Section Comment DEQ Response

The Center for Energy and Economic Development A1 General It is premature for Wyoming to take any administrative action on the RHR by choosing § 308 or § 309 as an option because of uncertainty created by American Corn Growers Assoc. v EPA, 291 F.3d 1 (D.C.Cir 2002) decision which invalidated RHR especially BART provisions. EPA’s approval of t he Annex on June 5, 2003 addressed the impact of the May 24, 2002 American Corn Growers Decision (Federal Register, Vol.68, No. 108, pages 33766

- 33767). The approval notice states, “The American Corn Growers court decision did not address the provisions in the regional haze rule allowing States to adopt a trading program or other alternative measures in place of source specific measures for BART sources.” The State of Wyoming has developed a SIP under Section 309 of the Regional Haze Rule based on years of work with the Grand Canyon Visibility Transport Commission (GCVTC) and the Western Regional Air Partnership (WRAP) that identified the best approach to address regional haze on the Colorado Plateau. The approach is flexible, and addresses all of the signif icant sources of haze in the west. The 309 approach also includes provisions allowing States to address other Class I areas beyond those on the Colorado Plateau. The American Corn Growers decision does not change these underlying reasons for implementing t he regional approach allowed under Section 309 of the Regional Haze Rule. The Center for Energy and Economic Development A2 General Wyoming should not commit to a specific regional haze implementation approach until after EPA has responded to the court’s remand of the RHR because § 309 is one of the BART provisions affected by Corn Growers decision

. Although CEED has filed a challenge to the Annex

- it is valid law until overturned/remanded. Pursuant to § 307(d)(7)(B) of the CAA [42 USC 7607(d)(7)(B)], “r econsideration of a rule shall not postpone the effectiveness of the rule. The effectiveness of the rule may be stayed by court order for up to 3 months.” There is no stay order in effect for these rules.

Arch Coal A3 General Dual SIPs The respondent alleges that because Wyoming’s Class I areas are not on the Colorado Plateau and that Section 308 of the Regional Haze Rule addresses all Class I areas that Wyoming will be required to submit a SIP under both Section 308 and 309 of the Regio nal Haze Rule. 40 CFR 51.309(g) allows a state electing to submit a SIP pursuant to Section 309 to make a declaration that it will address other Class I areas than those on the Colorado Plateau pursuant to the requirements of Sections 309(g)(2) and 309(g)( 3) rather than pursuant to Section 308. Wyoming has elected to do so.

### 2 Arch Coal A4 General Adjacent 308 States The SO 2 strategies are satisfied for Wyoming sources under the provisions of Section 309(g). Regardless of timing issues and the success of Senator Imhofe’s efforts, the states represented in the WRAP are committed to a coordinated effort to address NO x & PM stra tegies. Wyoming and all of its neighboring states are participants in the WRAP.



## B. **Analysis of 309(g) Comments received from the Forest Service letter dated October 19, 2006**

Commenter Comment # Section Comment DEQ Response

Forest Service B1 Natural Conditions It is important to provide a detailed description of the methods used to develop natural conditions. We encourage states to use calculations that are based on recommendations from the IMPROVE steering committee and the EPA

. The S tate was not involved in the development of the natural visibility conditions. The WRAP states utilized the conditions developed by EPA. The EPA relied heavily on the National Acid Precipitation Program (NAPAP) developed in 1990 to establish natural visi bility conditions for the Regional Haze SIP. The following website provides a detailed description of the NAPAP
program: http://www.epa.gov/airmarkets/resource/docs/NAPAP.pdf

. Forest Service B2 Emission Inventories It would be helpful if the State could spend a considerable effort describing how the inventories were developed. An entire chapter has been dedicated to describing the emissions inventory. Please see Chapter 4 of the SIP. Additional inventory information can also be found on the TSS site: ht tp://vista.cira.colostate.edu/TSS/Results/Emissions.aspx

Forest Service B3 BART BART source identification, elimination, and level determination will be of particular interest for review. Chapter 6 of the SIP provides a detailed description of analyses performed on BART sources.

Forest Service B4 Area of I nfluence We suggest that each state clearly identify and apportion by State, or other geographical means, the significant levels of pollutants contributed to each Class I area by source. Developing this information together with neighboring States and Tribes will facilitate consistency. Wyoming worked closely with other states and tribes to develop the significance levels of pollutants in each Class I area. The significance level of each pollutant w as developed by WRAP, which ensured consistency among the states. All of this information is compiled on the TSS website: http://vista.cira.colostate.edu/tss/Results/HazePlanni ng.aspx . The consultation process between Wyoming and surrounding states and tribes can be found in Chapter 11 of the SIP.

Forest Service B5 Reasonable Progress For Class I areas where the reasonable progress goal is more impaired than the uniform rate of progress, consider presenting information on a component basis. The State has presented the information on a component basis thr oughout the SIP. Figures 7.6

- 1 to 7.6

- 3 present the time series by pollutant for the 20% worst days, when the uniform

reason able progress goal was not met . Section 7.6 provides a demonstration that the reasonable progress goals set are reasonable. In this section there is component

- specific discussion.

### 3 Forest Service B6 Wildland Fire If anthropogenic fire contributes to the index used to track long

term reasonable progress in Class I areas, the visibility SIP should identify how it will be addressed. The SIP contains a section that addressed anthropogenic fire. Section 8.2.5 outlines the State’s agricultural and forestry smo ke management techniques. The DEQ has ensured tha t this smoke management program meets all of the requirements set forth by the Regional Haze Rule.

Forest Service B7 Regional Consistency The FS hopes that the states will work towards consistent descriptions of apportionment and emission control goals, thus resulting in development of similar progress goals, regardless of release dates. The inventories, monitoring and modeling was performed by WRAP to maintain consistency within the Western states . Wyoming has consulted with other states continuously throughout the SIP development process. Chapter 11 summarizes the consultation process.

Forest Service B8 Verification and Contingencies Given the uncertain future of any individual monitoring sit e, we suggest that the SIP address the representativeness of both primary and alternative data sites for each Class I area. The State has identified IMPROVE sites as the representative monitoring sites. It is believed that these sites appropriately capture emissions in all of the Class I areas. Since these are EPA

recognized monitoring sites that have been sited under the guidance of a steering committee, the Division does not find it necessary to consider alternative data sites.



## C. **Analysis of 309(g) Comments Received in Response to EPA Comment Letter Dated May 29, 2008** 

Commenter Comment # Section Comment DEQ Response

EPA C1 BART WRAP needs to justify using 0.5 deciviews as a threshold for determining whether sources are subject to BART. EPA’s BART guidelines state that “As a general matter, any threshold that you use for determining whether a source ‘contributes’ to visibility impairment should not be higher than 0.5 deciviews.” The guidelines give states the discretion to establis h a lower threshold “if they conclude that the location of a large number of BART

- eligible sources within the State and in proximity to a Class I area justify this approach. When developing the modeling protocols for the visibility analysis, the four part icipating states established the threshold at 0.5 deciviews because it is consistent with EPA guidelines, and is consistent with long

- standing visibility modeling practices. Significant BART

- eligible sources that are in pro ximity to Class I areas in the W est have been addressed through the reasonably attributable visibility impairment process, and there is not a large concentration of BART

- eligible sources that are in proximity to a Class I area. In addition, the backstop trading program will include all sources with emissions over 100 tons/year and will therefore still include sources that may not be subject to BART. The guidelines do not require states to establish a lower threshold, and the four participating states do not believe that a lower threshol d is needed or justified.

Language has been added to the Better Than BART demonstration to explain that the 0.5 deciview threshold is consistent with EPA’s BART guidelines.

### 4 EPA C2 BART When estimating BART emission reductions WRAP excluded

some non

- utility sources that it characterizes as potentially subject to BART and this is not consistent with regulatory requirements. The analysis excluded a small number of non

- utility sources that in aggregate represent 1% of the regional milestone. EPA has not establ ished a presumptive control level for these sources and there is little benefit to doing a case

- by

- case analysis because the results would have a negligible impact on the regional milestone. These sources will still be included in the Backstop Trading P ro gram.



## D. **Analysis of 309 (g)**  **Comments Received in Response to the October 27, 2009 Public Hearing**

Commenter Comment # Section Comment DEQ Response

Judith Hamm D1 General Concerned that particulate matter caused by quarries and road construction were not addressed as a contributing f actor of haze. There also does not appear to be any monitoring responsibilities applied to the quarry or construction operations. The emission s inventory developed by WRAP identifies construction emissions, as well as industrial activities, including mining and quarrying as particulate matter source categories. The entire list of source categories can be found in Table 2 of the dust emissions d ocument in WRAP’s technical support document ( http://vista.cira.colostate.edu/TSS/Results/Emissions.aspx “Emissions Methods”)

. Wyoming’s Air Quality Standards and Regulations (WAQSR ) Chapter 3
, Section 2
, contains Emissions Standards for Particulate Matter. Both construction activities and quarry operations fall under this chapter. Test method requirements for determining particulate matter emissions are found in Chapter 3, Section 2(h)(iii)

.
The SIP addresses road construction in Section 8.2: Required Factors for the Long

- Term Strategy. It is a requirement under Section 51.308(d)(3)(v) of the Regional Haze Rule for the SIP to consider measures to mitigate impacts of construction activities. Chapter 3, Section 2(f) of WAQSR addresses this requirement.

Please note that the day

- to

- day impacts of such facilities are not analyzed by the regional haze program. The region al haze program focuses on long

- term overall impacts of all sour ces combined at a reg ional level. The day

- to

- day responsibilities of the quarry are better addressed through the compliance program.

### 5 Commenter Comment # Section Comment DEQ Response

Wyoming Outdoor Council D2 General WOC believes that DEQ should plan for a visibility improvement of greater than 45% in this planning period

. The WRAP states have stressed that the Uniform Rate of Progress (URP) is not achieved in any of the western states because there are too many uncontrollable sources of emissio ns impacting visibility in the W est, overwhelming the contr ollable sources. As identified in the SIP, organic carbon from wildfires is the single biggest contributor to visibility impairment.

Section 51.308(d) of the Regional Haze Rule states that “ The reasonable progress goals must provide for an improvement in visibility for the most impaired days over the period of the implementation plan and ensure no degradation in visibility for the least impaired days over the same period ”. Therefore, the only days that are required to be analyzed for visibility are the worst and best days. Since there is no degradation in visibility for the 20% best days, this portion of the Rule is satisfied. During the 20% worst days, wildfires are a major contributing factor. Therefore, without the ability to control wildfires, it is difficult to demonstrate a greater than 45% improvement of visibility.

Please note that not all reductions were included in the WRAP modeling. The results do n ot include the BART and long

- term strategy reductions proposed in this SIP or any other WRAP SIPs. The WRAP could only include enforceable reductions that were on the books at the time of the last model run.

Wyoming Outdoor Council D3 General Since improvements of less than 1.0 dv are not apparent to most people, Wyoming Outdoor Council recommends that DEQ revise its SIP to achieve recognizable visibility improvements of 1.2 dv on the most impaired days

. With the exception of Yellowstone National Park and Grand Teton National Park and Wilderness Area, improvements of 1.2 dv would exceed t he URP goal. For Yellowstone and Grand Teton, a 1.2 dv decrease would result in projected visibility of 0.1 dv over the URP goal. It is explained in Chapter 7 of the SIP that Wyoming was not able to achieve its URP for the first planning period. Therefore, to improve visibility at a level greater than URP is also not viable in this planning period.

### 6 Commenter Comment # Section Comment DEQ Response

Wyoming Outdoor Council D4 General WOC recommends that DEQ focus greater attention on correcting haze during the winter months when fire is not likely a significant contributing factor, specifically in the Bridger and Fitzpatrick Wilderness areas

. Section 51.308(d) of the Regional Haze Rule states that “ The reasonable progress goals must provide for an improvement in visibility for the most impaired days over the period of the implementation plan and ensure no degradation in visibility for the least impaired days over the same period ”. Therefore, it is only required to analyze the monitored best and worst days. In the case of the best days, modeling de monstrates no further degradation of visibility. Since the worst days occurred in the summer months, focusing on correcting the winter months will have no impact on the results of the worst days modeling.

However, BART

- eligible sources identified in the S IP are required to control emissions year

ro und, and the Division is confident that the implementation of BART will have significant visibility impairment improvements in both the summer and winter months.

Wyoming Outdoor Council D5 Chapter 6: BART EPA has not approved Section 309, and therefore it cannot be relied on as BART. Under the Regional Haze Rule, the State is required to implement a plan that will reduce visibility impairment. This is occurring in two parts; Section 309 and Section 309(g). Under this rule, EPA allows the State to take credit for any SO 2 reduction achieved in section 309, as stated in 51.309(g)(i): “ In developing long term strategies pursuant to 51.308(d)(3), the state may build upon the strategies implemented under paragra ph 9(d) of this section, and take full credit for the visibility improvement achieved through these strategies.” There is no requirement in this rule that the State must have an EPA

- approved 309 program before it is relieved of its BART responsibility.

The original vision of the EPA Regional Haze Rule developed in 1999 was to complete Section 309 before 309(g), which enabled Section 309(g) to take credit for the SO 2 reductions. The original deadline for the 309 submittal was 2003, while 309(g) wasn’t d ue until 2008. Since this time, the State has submitted two SIPs to EPA and will submit its third revision in early 2011. EPA has also changed the Rule several times, and pushed back the 309 submittal until 2007. Due to delays, the process has been taki ng longer than expected and the 309 and 309(g) processes are now overlapping, and SIP submittal for both programs are occurring in parallel.

Wyoming Outdoor Council D6 General WOC suggests that companies are submitting BART with SO 2 controls that would achieve better reduction than Section 309, and therefore these proposals should be adopted because they are achieving greater reasonable progress than the 309
program

. The 309 program has undergone analysis to demonstrate that the prog ram is achieving reasonable progress that is better than BART. Please refer to the Demonstration that the SO 2 Milestones Provide Greater Reasonable Progress than BART in Appendix E. In this demonstration, the State not only verifies that the program meet s or exceeds presumptive SO 2 BART levels, but also provides other benefits of implementing the milestone program. One of these benefits includes limiting new source growth for SO 2 emissions in the participating

### 7 Commenter Comment # Section Comment DEQ Response states. In addition, the program includes e very source that emits 100 tons per year or greater of SO 2 , and therefore targets a greater number of sources than what would be identified in the BART program. Also, The 309 program does not only focus on stationary sources, but also includes strategies to address mobile sources, prescribed fire, pollution prevention, and Clean Air Corridors.

Wyoming Outdoor Council D7 General Since “the largest point source of NO x emissions is coal

- fired power plants”, WOC believes that controls on the Bridger and Naughton power plants should be a focus of DEQ

. The DEQ has incl uded these power plants as BART

- eligible sources, and has performed the appropriate BART analysis for both plants. The Naughton power plant has been required to install and o perate low NO x bu rners with overfire air on two of its units, and install and operate low NO x burners with overfire air and install selective catalytic reduction on the third unit. The overall NO x reduction from baseline achieved by these units is 10,525 TPY. These contr ol systems will be installed within 5 years of the SIP approval. The Bridger power plant is required to install and operate low NO x burners with overfire air on all fou r units. The overall reduction from baseline achieved by these four units is 13,749 TP Y. These systems have already been installed and performance tested for units 2

- 4, and will be installed with in 5 years of SIP approval for U nit 1. In addition to these BART requirements, the State will require the Jim Bridger units to install selective c atalyti c reduction as part of the long

- term strategy.

Wyoming Outdoor Council D8 Oil and Gas Sources Since oil and gas sources are the second largest category of stationary sources, WOC believes that DEQ needs to pursue regulation of this industry, such as adoption of BACT requirements, codifying its offsets policy, and regulating drill rigs

. DEQ agrees that it is important to recognize and regulate oil and gas emis sions. As outlined in the long

- term strategy portion of the SIP, DEQ cannot complete the eval uation of oil and gas impacts on visibility until Phase III of the WRAP study has been complete d . In terms of adoption of BACT requirements, WAQSR Chapter 6
, Section 2
, already contains the permitting BACT requirements for oil and gas production facilitie s. DEQ also agrees that policies and regulations for oil and gas sources need to be codified, and are in the process of doing so as ozone is addressed.

Wyoming Outdoor Council D9 Chapter 2: Monitoring WOC states that it is widely recognized (especially by the Forest Service) that the Bridger IMPROVE site is not appropriately located to monitor the contribution of oil and gas emission s in the field. WOC suggests that there is a need for visibility monitoring that reflects the oil and gas field. The Forest S ervice has added an additional IMPROVE monitor at a location that is believed to capture oil and gas impacts on the Bridger Wilderness area. The new monitor is located at Boulder Lake, and the Forest Service has been collecting data from the monitor since August 2009.

### 8 Commenter Comment # Section Comment DEQ Response

Wyoming Outdoor Council D10 General WOC’s statement: “DEQ claims that air quality is good in Wyomin g, much better than in the east . The implication is we should be happy with what we’ve got and not worry about Wyoming making as much progress as URP calls for”

. DEQ is not in any way trying to imply that “we should be happy with what we’ve got and not worry about Wyoming making as much progress as URP calls for”. DEQ is simply trying to demonstrate that it is not as easy to show progress when there are fewer initial visibility impacts. It is much easier to show increased original progress when there are greater impacts. In addition, there is a large difference in vegetation and meteoro logical conditions between the East and the W est. For ex ample, in comparison to the E ast , the Class I areas in Wyoming are located in more heavily forested areas, and therefore more natural fires occur within the Class I area proximity. The low humidity in the West also allows for a more noticeable difference in the visibility when such an ev ent occurs. The DEQ is not making excuses for not achieving URP goals and the Division does take the goal very seriously. The DEQ simply wanted to explain in the SIP why oth er states such as those in the E ast may be able to meet the URP in the initial ph ase, while Wyoming and other Western states were not.

Wyoming Outdoor Council D11 Chapter 6: BART Coal

- Fired Power Plants Wyoming Outdoor Council believes that coal

- fired power plants should use Selective Catalytic Reduction (SCR) NO x Control technology to meet EPA presumptive BART lim it (which is not believed to be met with current BART that the State is proposing). WOC believes this is particularly important for the plants that do not have additional NO x controllers as part of its l ong

- term strategy (Dave Johnston, Wyodak and Naughton). When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulations (WAQSR), as well as EPA’s Subpart Y Guidance. Each source underwent permitting an d went out for public comment

. DEQ responded to each comment. All comments and responses can be found in the TSD, under Chapter 11
, Summary of FLM (and Other) Comments on BART and State Responses on BART

. Permit appl ications and the DEQ analysis for each BART source can be f ound in Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp

.

Wyoming Outdoor Council D12 Chapter 6: BART Coal

- Fired Power Plants DEQ is proposing BART limits that are lower than the NSPS of 0.11 lb/MMBTU established by EPA

. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulations (WAQSR), as well as EPA’s Subpart Y Guidance. Each source underwent permitting an d went out for public comment

. DEQ responded to each comment. All comments and responses can be found in t he TSD, under Chapter 11
, Summary of FLM (and Other) Comments on BART and State Responses on BART

. Permit applications and the DEQ analysis for each BART source can be found in Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp

.

Wyoming Outdoor Council D13 Chapter 6: BART Coal

- Fired Power Plants WOC pointed out a number of ways in which particulate matter control could be achieved, specifically through the installation of full scale baghouse technology or polishing baghouses. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulat ions (WAQSR), as well as EPA’s S ubpart Y Guidance. Each source underwent permitting an d went out for public comment

. DEQ responded to each comment. All comments and responses can be found in the TSD, under Chapter 11
, Summary of FLM (and Other) Comments on BART and State Responses on BART

. Permit applicatio ns and the DEQ analysis for each BART source can be f ound in Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp

.

### 9 Commenter Comment # Section Comment DEQ Response

Wyoming Outdoor Council D14 Chapter 6: BART Trona Plants WOC believes that the lack of BART for the Granger facility is shortsighted and illegal. It is believed that the facility should be analyzed as a small group of facilities with the other two Trona plants in the area. Although the Regional Haze Rule does not require this, WAQSR Chapter 9 does require BART if all facilities are grouped together. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulations (WAQSR), a s well as EPA’s S ubpart Y Guidance. Each source underwent permitting an d went out for public comment

. DEQ responded to each comment. The public hearing for the Granger facility occurred on September 11, 2008
, in Rock Springs
, WY. All comments and res ponses can be found in the TSD, under Chapter 11
, Summary of FLM (and Other) Comments on BART and State Responses on BART

. Permit applications and the DEQ analysis for each BART source can be found in Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp

.

EPA D15 Chapter 5: Modeling The modeling performed by WRAP was not representative of all of the controls implemented under the regional haze program. EPA suggests the State consider remodeling as part of the five

- year review

. The State of Wyoming has not planned to do any additional modeling. All modeling was performed by WRAP on a regional level. WRAP currently does not have the budget to do any additional modeling, but has made a request to EPA for more funding.

EPA D16 Chapter 4: Statewide Emissions Inventory Although overall state SO 2 and NO x projected emissions decrease, Tables 4.2.1 and 4.3

- 1 show increase in area SO 2 emissions and in area and oil and gas emission s by 2018. Chapter 5 modeling also shows increase in impacts in all 3 Wyoming Class I areas for SO 2 on the 20% best and worst days. Modeling also shows increase in impacts for NO x on the 20% worst days in Yellowstone National Park and Bridger Wilderness a rea. The State needs to address the impacts in Class I areas from area and oil and gas sources, including enforceable emission limitations, compliance schedules and other measures as necessary. The State of Wyoming appreciates the level of detail that EPA used when reviewing the SIP. When the State investigated the cause of the SO 2 area source increase, it was found that the increase was due to growth factors applied by WRAP in the inventory. Of the 6,300

- ton increase, 4,800 tons of it came from residua l oil burners, and 900 tons from industrial distillate oil. Wyoming does not have any of these sources, so the growth factor does not apply and these emissions were removed from the ca lculations. The additional 600

- ton increase came from commercial coal, i ndustrial processes, and drill r ig gro wth. Wyoming does have these sources, so the 600

- ton increase will remain in the calculations. The appropriate tables have been up dated to reflect these changes.

In terms of the NO x increase, the State is in a diff icult position since the Division is hoping to combine efforts for ozone and regional haze as a more efficient strategy and ozone is the driving force in this process.

In terms of the oil and gas increase, DEQ agrees that it is important to recognize and regulate oil and gas emis sions. As outlined in the long

- term strategy portion of the SIP, DEQ cannot complete the evaluation of oil and gas on visibility until Phase III of the WRAP study has been complete d

.

### 10 Commenter Comment # Section Comment DEQ Response

EPA D17 Chapter 6: BART EPA previously commented on Wyoming’s BART determination. See attached letters

. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulat ions (WAQSR), as well as EPA’s S ubpart Y Guidance. Each source underwent permitting an d went out for public comment

. DEQ responded to each comment. All comments and responses can be found in the TSD, under Chapter 11
, Summary of FLM (and Other) Comments on BART and State Responses on BART

. Permit applications and the DEQ analysis for each BART source can be f ound in Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp

.

EPA D18 Chapter 6: BART The State is relying on two documents for BART determination: the BART application submitted by source, and the analysis of the BART application performed by the State. These documents need to be submitted with the SIP

. Both of these documents will be in cluded in the SIP for each BART determination. The analysis of the BART determinations and applications for each eligible source can be found in Attachment A of the SIP at: http://deq.state.wy.u s/aqd/regionalhaze.asp

.

EPA D19 Chapter 7: Reasonable

Progress

Goals EPA has pointed out that SO 2 controls need to be evaluated in

non

- Plateau Cl ass I areas as part of the long

- term strategy and reasonable progress goals. The State must provide a demonstration of how Section 309 strategies, including the Backstop Trading P rogram are meeting visibility goals, and an analysis of whether other SO 2 controls are needed to meet reasonable progress. EPA also notes that since the reasonable progress goals are less than URP goals, stationary sources that are not required to implement SO 2 BART controls, and other source categories of SO 2 still have to be considered and addressed for the purpose of reasonable progress. The State has modeled visibility in the additional non

- plateau Class I area monitor locations. Wyoming Class I areas and Class I areas in surrounding states were included in the modeling. Table 6.2

- 2, demonstrates visibility broken down by sulfate extinction only. It can be seen in this table that all Class I areas show visibility improvement for the worst days, and no degradation in visibility for the best days, thereby meeting the requirements outlined in the Regional Haze Rule. In addi tion, Table 6.2

- 1 outlines the R egional SO 2 Emissions a nd Milestone R eport summary. This table demonstrates that the 309 states have had significant SO 2 reduction and have more than exceeded the goals set by the program.

The Regional Haze Rule requires that the above demonstration is necessary, as well as a demonstration that the milestone provides greater reasonable progress than BART. This demonstration can be found i n Appendix E, Demonstration that the SO 2 Milestones Provide Greater Reasonable Progress than BART. As long as this demonstration is performe d, u nder the Regional Haze Rule, EPA allows the State to take credit for any SO 2 reduction achieved in section 309, as stated in 51.309(g)(i): “ In developing long term strategies pursuant to 51.308(d)(3), the state may build upon the strategies implemented under paragraph 9(d) of this section, and take full credit for the visibility improvement achieved through these strategies.” However, if the URP goal is not met, the Rule does not require SO 2 sources to undergo further reduction in order to meet this go al. If the URP goal cannot be met for a given planning period, it is the requirement that the State demonstrate why this goal cannot be met, which the State believes it has done throughout the SIP.

### 11 Commenter Comment # Section Comment DEQ Response Therefore, the State believes that all requirements of the Regional Haze Rule as it relates to the 309 strategies for meeting visibility goals have been met and the SO 2 sources do not require further analysis.

EPA D20 Chapter 7: Reasonable

Progress

Goals For Q/d calculations, FLM’s proposed FLAG guidance amendments specify inclusion of direct PM and H 2 SO 4 (in addition to SO 2 and NO X ) and use of a consistent baseline across all sources

. The EPA Regional Haze Rule did not provide guidance o n source selection for the four

- factor analysis. Therefore, the Stat e looked at the best way to perform an estimate that would capture the emissions in the WRAP inventory. DEQ did not include H 2 SO 4 because it is not a pollutant that was included in the WRAP inventory. PM was not used for source selection because the WRAP inventory is incomplete for this pollutant. Since SO 2 was addressed in the 309 portion, DEQ believed that the evaluation of NO x was a reasonable first step in determining sourc es that should undergo the four

- factor analysis. Although PM was not used
to determine source selection, it was addressed when determining the potential control strategies.

EPA D21 Chapter 7: Reasonable

Progress

Goals For Q/d Calculations, EPA does not believe it is appropriate to separate individual units for emission calculations at the EGUs

. DEQ believed that it was appropriate to separate individual units for tw o reasons, t he first being that the BART analysis addressed individual units, so this process was done the same in order to maintain cons istency. Secondly, not all EGU s a re controlled the same, so DEQ believed it was appropriate to look at each unit separately . Using this strategy, all EGU s in Wyoming were either captured by BART or by the four

- factor analysis.

EPA D22 Chapter 7: Reasonable

Progress

Goals Wyoming needs to provide additional justification for the selection of Q/d>10 as a screening threshold, such as a reasonable analysis of relative emissions/impacts of sources captured by different levels of Q/d versus sources not captured. Wyoming selected Q/d>10 as a screening threshold based on the Federal Land Manager’s recommendations. When the State used this threshold it was found that all BART sources were captured along with other sources , and therefore DEQ determined that this threshold was a good place to sta rt . DEQ agrees that there needs to be a better screening pro cess as it goes forward to address regional haze in future SIP reviews.

EPA D23 Chapter s 7 and 8: Reasonable

Progress Goals & Long Term Strategy In SIP section 8.3.4, DEQ states “ The Division will be developing a state rule to obtain authority to further evaluate

non

- BART sources identified in the four

- factor analysis for retrofits. The rulemaking will require an estimate of the expected visibility benefit associated with east retrofit. The
Divis ion will complete this rulemaking by the next scheduled plan update in 2013”

. EPA indicates that the Regional Haze
R ule does not allow for commitments to implement strategies at some later date that are identified under reasonable progress or for the State to make such commitments. In This language has been removed and replaced with the following: The Air Quality Administrator cannot, per Wyoming Statute 35

- 11

- 202, establish emission control requirements except through state r ule or regulation. Furthermore, the Wyoming statute requires the Administrator to consider the character and degree of injury of the emissions involved. In this case, visibility modeling would be required to assess the degree of injury caused by the emis sions. Modeling is not available at this time to determine impacts from emission reduction. The state believes it has taken a strong and reasonable first step in identifying potential contributors to visibility impairment, and that the next step of creat ing an appropriate rule or regulation will be accomplished in the next SIP revision. The visibility progress was designed as a long

- term program going out to 2064.

### 12 Commenter Comment # Section Comment DEQ Response
addition, the control measures identified in the four

- factor analysis need to be incl uded and made enforceable as part of the long

- term strategy.

EPA D24 Chapter 8: Long

- Term

Strategy In the SIP DEQ states in section 8.2.6 “ Wyoming has ensured that all existing emission limitations and control measures, for which the state of Wyoming is responsible, used to meet reasonable progress goals are enforceable either through the WAQSR or SIP measures approved by the EPA”

. EPA indicated that th e State cannot take credit for limitations or control measures that are only enforceable at the State level and that are not federally enforceable. This language has been removed from the SIP and replaced with the following: Wyoming has ensured that all e xisting emission limitations and control measures, for which the State of Wyoming is responsible, used to meet reasonable progress goals are enforceable at the State level through the Wyoming Air Quality Standards and Regulations (WAQSR) or State

- issued
pe rmits. Once EPA approves this SIP, these measures will be federally enforceable. (This language was f urther revised at a later date.)

EPA D25 Chapter 8: Long

- Term

Strategy The controls for Laramie River Station and Jim Bridger need to be implemented under BART in this SIP and the implementation of controls cannot be postponed until some later date under reasonable progress. This issue has been appealed through the Environmental Quality Council (EQ C) and will be resolved at the S tate level through the EQC. The State is still negotiating the details.

PacifiC orp D26 Chapter 6: BART PacifiC orp does not believe it is appropriate for the Division to propose the Regional Haze SIP until BART determinations are final. The State has a deadline with EPA for when the SIP must be completed, and therefore the BART determinations and the SIP must be done on a parallel path. It was initially expected that BART would be finalized first, b ut the determinations took much longer than expected, especially with appeals underway fo r a number of the BART permits.

PacifiC orp D27 Chapter 8: Long

- Term

Strategy PacifiC orp believes that the Division sho uld exercise more flexibility in setting long

- term strategy requirements than what is currently reflected in specific dates of NO X reductions assigned to the four Jim Bridger power plant units. The emission rates and timing should be determined by the four or five factor tests, which will be undertaken at the time of the permit submittal. This issue has been appealed through the Env ironmental Quality Council (EQ C) and will be resolved at the S tate level through the EQC. The State is still negotiating the details.

### 13 Commenter Comment # Section Comment DEQ Response

PacifiC orp D28 Chapter 8: Long

- Term

Strategy PacifiC orp believes the term “lowest viable” is not believed to be the proper standard to determine NO X reductions, and is subject to the varying interpretations in the SIP. This language has been removed from the SIP

.

PacifiC orp D29 Chapter 6: BART Once BART determinations are final, state and federal rules require BART controls to be implemented “as expeditiously as practicable, but no later than 5 years after approval”. By contrast, rules governing the Region al Haze SIP require that a long

- term st rategy include “enforceable emissions limitations, compliance schedules and other measures as necessary to achieve reasonable progress goals....”. The emission limits and timing provisions for the Jim Bridger power plant go beyond both of these requirements

. The SIP has been revised to remove the set dates of BART control implementation and replaced with “as expeditiously as practicable, but no later than 5 years after approval”

.

PacifiC orp D30 Chapter 6: BART PacifiC orp does not believe that tuning existing LNB and OFA and installing SCR with an emission limit of 0.07 lb/MMBtu for the Naught on Power Plant is BART. PacifiC orp has demonstrated that tuning the existing LNB with OFA and an emission rate of 0.035 lb/MMBtu is BART

. DEQ does not agree. When deter mining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulations (WAQSR), as well as EPA ’s S ubpart Y Guidance. Each source underwent permitting an d went out for public comment

. DEQ responded to each comment. The public hearing for this permit occurred on August 4, 2009
, in Kemmerer
, WY. All comments and responses can be found in the TSD, under Chapter 11
, Summary of FLM (and Other) Comments on BART and State Responses on BART

. The permit application and State analysis can be found in Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp

.

PacifiC orp D31 Chapter 6: BART PacifiC orp disagrees with the conclusion that a NO x removal cost of $2

, 830 per ton is reasonable for the Naughton power plant. Appendix Y contemplates a removal cost of $100

- $1000 per ton of NO x removal is reasonable. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulat ions (WAQSR), as well as EPA’s S ubpart Y Guidance. Each source underwent permitting an d went out for public comment

. DEQ responded to each comment. The public hearing for t his permit occurred on August 4, 2009 in Kemmerer, WY. All comments and responses can be found in the TSD, under Chapter 11 , Summary of FLM (and Other) Comments on BART and State Responses on BART

. The permit application and State analysis can be found i n Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp

.

### 14 Commenter Comment # Section Comment DEQ Response

National Park and Fish and Wildlife Services D32 General Overall, DOI stated that the draft implementation plan was well organized, recognizing that Wyoming is committed to significant point source emission reductions. DOI was pleased with these reductions and recommend the State highlight total expected reductions in a summary table. The State appreciates the fact that DO I recognizes the significance of the reductions made in this first SIP. The National Park Service and US Fish and Wildlife have been involved in the WRAP process from the beginning and have a good sense of the progress achieved. They also understand that not all emission reductions will occur in the first planning period, and that the Regional Haze Rules allow for emission reductions out to 2064.

National Park and Fish and Wildlife Services D33 General DOI is concerned that Wyoming relied on the 309 SIP to address impacts from sulfur dioxide, pointing out that the 309 SIP focuses on Class I areas on the Colorado Plateau. Wyoming did rely heavily on the 309 SIP to address impacts from sulfur dioxide. Th e Rule allows the State to take credit for SO 2 reductions from the 309 program to show progress in Wyoming’s Class I areas. The State of Wyoming would not have participated in the 309 program in the first place if meaningful reductions were not anticipate d at the monitors in Wyoming Class I areas. Wyoming Class I areas all show improvement with respect to sulfate extinction as a result of the 309 program. This improvement has been documented in the 309(g) SIP (see Table 6.2

- 2). The Regional Haze Rule al lows the State to take credit for the 309 improvements when addressing 309(g) requirements.

National Park and Fish and Wildlife
Services D34 Oil and Gas DOI is concerned about projected increases in NO x emissions by 2018 from oil and gas activities. The State is also concerned about projected increases in NO x from oil and gas activities. The State has been working continuously to develop better estimates of emissions from this sector. The W RAP has also been working on a P hase III estimate with the oil a nd gas industry to better characterize the emissions from all of the western gas fields. This information has not been completed, but it will be used in future SIP efforts.

National Park and Fish and Wildlife Services D35 Chapter 6: BART DOI references previous comments regarding BART determinations. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulat ions (WAQSR), as well as EPA’s S ubpart Y G uidance. Each source underwent permitting an d went out for public comment

. DEQ responded to each comment. All comments and responses can be found in the TSD, under Chapter 11
, Summary of FLM (and Other) Comments on BART and State Responses on BART . The permit application and State analysis can be found in Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp

.

### 15 Commenter Comment # Section Comment DEQ Response

National Park and Fish and Wildlife
Services D36 Chapter 3: Pollutants

Causing Visibility Impairment DOI would like the State to include in Chapter 3 a brief description of how light extinction and deciviews are calculated from IMPROVE measurements instead of putting it in Chapter 13 which includes explanatory info rmation on IMPROVE monitoring. The State will include some additional explanatory information on IMPROVE in Chapter 3 and a cross reference for more detail in Chapter 13.

National Park and Fish and Wildlife
Services D37 Chapter 4: Statewide Emissions Inventory DOI would like the State to clarify in Chapter 4 which inventories were used for various modeling exercises, rather than sending the reader to the Technical Support Document. The DOI is also pointing out that the 2018PRP inventory has

some uncer tainties, especially relating to the oil and gas indu stry, and that perhaps the 2018 PRP inventory underestimates oil and gas projections. The State will include clarifying language in Chapter 4 on which inventories were used for the various modeling runs and an explanation for readers who were not involved in the WRAP process for why there are multiple inventories and multiple model runs.

The State agrees that there are uncertainties associated with the 2018PRPb inventory, but it was the best inventory available at the time of the last model run the WRAP was able to do. Furthermore, while it is not perfect, it is a huge improvement over the regional scale emission inventories generated at the beginning of the regional haze process. All emission invento ries have uncertainties, and this very large regional scale inventory is no exception. Oil and gas projections for the West are just one area that needs refinement. The western states are currently participating i n a P hase III oil and gas inventory updat e and that information was not available at the time the last model run required for the SIP (2018PRPb) was completed. Since that study has not been completed, the State canno t say at this time whether the P hase III estimates will increase or decrease emi ssions.

National Park and Fish and Wildlife
Services D38 Chapter 5: Source Apportion me nt

and Regional Haze Modeling DOI is simply making comments about differences in results between CAMx

- PSAT and CMAQ and WEP modeling tools used by the WRAP. There is a req uest for a discussion on how relative response factors are calculated. The DOI points out that in spite of decreases in sulfates and nitrates, Wyoming Class I areas will not achieve the uniform rate of progress. The DOI recommends that the State explain that the WRAP model results used by all 13 WRAP states do not include final BART determinations for most of the states, including Wyoming. The State will include in Chapter 5 an explanation for how relative response factors were calculated by the WRAP. DOI’s comment on the fact that decreases in nitrate and sulfate extinction does not result in achieving the uniform rate of progress is an im portant one. The WRAP states have stressed the fact that the uniform rate of progress is not achieved in any of the western states because there are too many uncontrollable sources of emissions impacting visibility in the West, overwhelming the controllab le sources. The State has pointed out in numerous places in this SIP that organic carbon from wildfires is the single biggest contributor to visibility impairment.

The State will include more discussion in Chapter 5 for those that were not involved in t he WRAP process, pointing out that the modeling results and all of the graphics associated with

### 16 Commenter Comment # Section Comment DEQ Response the modeling results do not include the BART and Long

- Term Strategy reductions proposed in this SIP or any other WRAP SIPs . The WRAP could only include enforc eable reductions that were on the books at the time of the last model run.

National Park and Fish and Wildlife Services D39 Chapter 6: BART DOI previously submitted comments on BART during the BART permitting process. DOI would like to see the cumulative NO x reductions from BART at the end of Chapter 6. The question was also asked if actual emissions or milestone commitments were used in the SO 2 2018 inventory, since actuals are lower than milestone numbers. All comments on BART determinations are being addressed through a parallel permitting process for BART. All comments and responses can be found in the TSD, under Chapter 11
, Summary of FLM (and Other) Comments on BART and State Responses on BART

.
Cumulative NO x reductions from BART are already included at the end of Chapter 8 showing the relative reduction from BART and Long

- Term Strategy. A figure showing just BART reductions will be included at the end of Chapter 6 as requested.

Since the WRAP d oes not have “actual emissions” for 2018 since it is in the future, the WRAP had to use milestone commitments in the 2018 emission inventories. An explanation will be added to the footnotes in Table 6.2

- 2.

National Park and Fish and Wildlife
Services D40 Ch apter 7: Reasonable

Progress

Goals DOI again requests explanation in the text in Chapter 7 that reasonable progress goals are based on the only modeling available and that actual reductions may be greater than those modeled.

DOI believes that because Wyoming’s Class I areas do not achieve the uniform rate of progress that the reasonable progress analysis needs to consider SO 2 controls for facilities not already addressed in Wyoming’s 309 SIP. That participating in the 309 program does not exempt Wyom ing from considering how emission reductions from 309 and potentially additional reductions could protect Class I areas not on the Colorado Plateau. DOI wants more information from the 309 SIP included in this SIP explaining emission reductions expected. Also, DOI would like to see a reference to Table 7.2

- 1. A sentence has been added to Section 7.5 explaining that results of RPGs listed in Table 7.5

- 1 do not include any additional controls beyond WRAP 2018b modeling.

Wyoming’s Class I areas do not achie ve the uniform rate of progress, nor do any of the Class I areas in the West, but it is not because of SO 2 impacts. The regional analysis of impacts on Wyoming’s Class I areas show that smoke from wildfires on federal lands is the most important factor in the State not achieving the uniform rate of progress. Until we are able to do something to control smoke from wildfires, we are not going to be able to achieve the uniform rate of progress. The uniform rate of progress is not a very useful tool in asses sing success in the West in dealing with regional haze.

With respect to considering how emissions reductions from 309 impact Class I areas off the Colorado Plateau, Wyoming has been very interested throughout the process. The State of Wyoming would not ha ve participated in the 309 program in the first place if meaningful reductions were not anticipated at the monitors in Wyoming Class I areas. Wyoming Class I areas all show improvement with respect to sulfate extinction as a result of the 309 program. Thi s improvement has been documented in the 309(g) SIP (see Table 6.2

- 2). The Regional Haze

### 17 Commenter Comment # Section Comment DEQ Response Rule allows the State to take credit for the 309 improvements when addressing 309(g) requirements. There is nothing in the Regional Haze Rule that says if the unifor m rate of progress has not been met, that those credits cannot be taken. There is nothing in the Regional Haze Rule that says that the State has to meet the uniform rate of progress; it says that if the State cannot achieve that rate, it must explain why, and that has been done in Chapter 5, Section 5.3.

Answers to all of the questions posed about reductions in SO 2 from the 309 program can be found in the 309 submittal package to EPA.

National Park and Fish and Wildlife
Services D41 Chapter 7: Reasonable

Progress

Goals DOI describes the process the State used in analyzing sources for reasonable progress. They would like to see a reference in Chapter 7, Section 7 to where the outcome of the reasonable progress analysis is provided. Several references to Section 8.3.4 have been added to Chapter 7, Section 7.

National Park and Fish and Wildlife
Services D42 Chapter 8: Long

- Term

Strategy DOI discusses how Wyoming has addressed impacts to Class I areas outside of Wyoming and how Wyoming addressed impacts from outside the state to the Wyoming Class I areas, including emissions from other countries and the shipping industry which are the resp onsibility of EPA. Again, DOI states that Wyoming needs to consider what additional controls not considered in the 309 SIP are feasible. Wyoming’s Class I areas do not achieve the uniform rate of progress, nor do any of the Class I areas in the West, bu t it is not because of SO 2 impacts. The regional analysis of impacts on Wyoming’s Class I areas show that smoke from wildfires on federal lands is the most important factor in the State not achieving the uniform rate of progress. Until we are able to do something to control smoke from wildfires, we are not going to be able to achieve the uniform rate of progress. The uniform rate of progress is not a very useful tool in assessing success in the West in dealing with regional haze.

With respect to consider ing how emissions reductions from 309 impact Class I areas off the Colorado Plateau, Wyoming ha s been very interested throughout the process. The State of Wyoming would not have participated in the 309 program in the first place if meaningful reductions w ere not anticipated at the monitors in Wyoming Class I areas. Wyoming Class I areas all show improvement with respect to sulfate extinction as a result of the 309 program. This improvement has been documented in the 309(g) SIP (see Table 6.2

- 2). The Regi onal Haze Rule allows the State to take credit for the 309 improvements when addressing 309(g) requirements. There is nothing in the Regional Haze Rule that says if the uniform rate of progress has not been met, that those credits cannot be taken. There is nothing in the

### 18 Commenter Comment # Section Comment DEQ Response Regional Haze Rule that says that the State has to meet the uniform rate of progress; it says that if the State cannot achieve that rate, it must explain why, and that has been done in Chapter 5, Section 5.3.

Answers to all of the questi ons posed about reductions in SO 2 from the 309 program can be found in the 309 submittal package to EPA.

National Park and Fish and Wildlife
Services D43 Chapter 8: Long

- Term

Strategy DOI says the oil and gas development and production are important sources of NO x . Wyoming should work closely with the oil and gas industry to develop better estimates of emissions growth. Furthermore, DOI speculates that WRAP phase II inventory underestimates NO x emissions for 2018. Wyoming is well aware that oil and gas development and production are important sources of
NO x . The State has been working continuously to develop better estimates of emissions from this sector. The W RAP has also been working on a P hase III estimate with the oil and gas industry to better characterize the emissions from all of the western gas fields. This information has not been completed, but it will be used in future SIP efforts.

National Park and Fish and Wildlife
Services D44 Chapter 8: Long

- Term

Strategy DOI seems to understand that the State is currently working on reductions from the oil and gas industry in response to ozone nonattainment issues. They ask that the State ask industry to offset emissions prior to regulatory r equirements. DOI further understands that Wyoming lacks regulatory authority to impose additional controls on non

- BART sources, underscoring that it is important to revisit the control options
in 2013. Wyoming is already implementing an interim policy on emission offsets. As far as we are aware, it is the only place in the country where minor sources of oil and gas are being offset.

National Park and Fish and Wildlife
Services D45 Chapter 8: Long

- Term

Strategy DOI has requested a table to support Figure 8.3.6

- 7 to help understand the magnitude of expected emissions reductions from BART implementation and long

- term strategy. Table 8.3.6

- 7 will be inserted to support Figure 8.3.6

- 7. (The Division decided at a later date not to add this table.)

### 19 Commenter Comment # Section Comment DEQ Response

US Forest

S ervice D46 General The RH SIP does not appear to address visibility impacts at the Savage Run Wilderness Area. Although this Wilderness area is not one of the 156 Federal Class I areas, the State of Wyoming has determined that it should be managed as a Class I area. The Regional Haze Rule only requires the State to address impacts at the mandatory Federal Class I areas, as stated in 51.308(d): “ The State must address regional haze in each mandatory Class I Federal area located within the State and in each man datory Class I Federal area located outside the State which may be affected by the emissions from within the State”. Since the Savage Run Wilderness area is not one of the 156 mandatory Class I Federal area, it will not be evaluated in this SIP.

US Fores t

Service D47 General Multiple air quality modeling exercises (PRB Coal, Pinedale Anticline, and others) identify potential ongoing visibility impacts in Class I areas within Wyoming and in adjacent stat es. The FS believes that the results of this modeling could benefit Wyoming in designing Reasonable Progress strategies. Wyoming relied on the modeling performed by WRAP for the development of the Regional Haze SIP. It was more logical for the State to use WRAP ’ s complete air quality model rather than piecin g together other multiple modeling exercises. The WRAP model allows Western States to compare results obtained using identical modeling methodologies. Wyoming does not plan on utilizing results obtained from the National Environmental Policy Act (NEPA)
E nvironmental Impact Statements (EISs). These documents are to be used as a decision making tool, and not an implementation planning and regulation development tool. All information contained in EISs is pre

- decisional until a draft has been released to th e public and is not approved until a record of decision is released.

US Forest

Service D48 Chapters 4 & 5 Tables 4.2

- 1 and 4.3

- 1 show project ed decreases in overall
state SO x and NO x emissions. However, the same tables show
increases in SO x emissions from area sources and NO x emissions from area sources and oil and gas sources by 2018. The subsequent model results (Figures 5.2.1

- 1, etc .) show
increases in SO x impacts from Wyoming on the best and worst 20% days in all three Wyoming Class I a reas. The FS believes that increasing Wyoming’s impacts at Class I areas cannot be understood to be reducing Wyoming’s “share of the emission reductions”. When the State investigated the cause of the SO 2 area source increase, it was found that the
increas e was due to growth factors applied by WRAP in the inventory. Of the 6,300

- ton increase, 4,800 tons of it came from residual oil burners, and 900 tons from industrial distillate oil. Wyoming does not have any of these sources, so the growth factor does no t apply and these emissions were removed from the ca lculations. The additional 600

- ton increase came from commercial coal, i ndustrial processes, and drill r ig growth. Wyoming does co ntain these sources, so the 600

- ton increase will remain in the calculat ions. The appropriate tables have been up dated to reflect these changes.

In terms of the NO x increase, the State is in a difficult position since the Division is hoping to combine efforts for ozone and regional haze as a more efficient strategy and ozone is the driving force in this process.

In terms of the oil and gas increase, DEQ agrees that it is important to recognize and regulate oil and gas emis sions. As outlined in the long

- term strategy portion of the SIP, DEQ cannot

### 20 Commenter Comment # Section Comment DEQ Response complete the evaluation of oil and gas on visibility until Phase III of the WRAP study has been complete d

.

US Forest

Service D49 Figure 5.2.8

- 3 How can “natural fire” be such a dominant fraction on the 20% best days at the BRID monitoring site? The cleanest days at Bridger principally occur in the winter when “natural fire” is rare compared to residential wood burning for example? Figure 5.2.8

- 3 represents weighted emissions. This means that both emissions totals and the probability of it spending time in the given area were modeled. This figure represents that Wyoming is the biggest contributor to elemental carbon in t he Bridger and Fitzpatrick Wilderness are a, and that the greatest percentage of elemental carbon is at tributed to wildfires. The Division is not trying to suggest that elemental carbon is the cause of impairment on the 20% best days

.
It can be seen from t he monitoring graphs: http://vista.cira.colostate.edu/TSS/Results/HazePlanning.aspx that while many of the best days occur in the winter months, some occur in the summer, which c an be seen particularly in 1998. On those days, elemental carbon is not one of the largest contributors.

US Forest

Service D50 Chapter 7 Wyoming’s 309 status does not absolve Wyoming of its requirement to perform a reasonable progress analysis for SO 2 at Class I areas that are not part of the 16 Colorado Plateau Class I areas. Reasonable progress has been analyzed for Class I areas in Wyoming and surrounding states that are not included in the Colorado Plateau boundaries. Table 6.2

- 2 summarizes the

mo deling results by sulfate extinction. Section 51.308(d) of the Regional Haze Rule states that

“ the reasonable progress goals must provide for an improvement in visibility for the most impaired days over the period of the implementation plan and ensure no degradation in visibility for the least impaired days over the same period ”. It can be seen on the Table that visibility in the Class I areas improved on the worst days, and did not have any degradation on the best days. In fact, many of the Class I area s showed improvement on the best days, thereby exceeding the expectations. The DEQ believes that this demonstration is an adequate reasonable progress analysis for SO 2 emissions in the Class I areas outside of the Colorado Plateau.

US Forest

Service D51 Chapter 7 Has Wyoming demonstrated that its plan represents greater visibility improvem ents than is expected to result from implementation of other requirements of the CAA (40CFR 51.308(d)(1)(iv))? For example, Table 4.3

- 1 lists roughly 24,000 tons per ye ar (TPY) of NO x increase from area and oil When the State investigated the cause of the SO 2 area source increase, it was found that the increase was due to growth factors applied by WRAP in the inventory. Of the 6,300

- ton increase, 4,800 tons of it came from residual oil burners, and 900 tons from industrial distillate oil. Wyoming does not ha ve any of these sources, so the growth factor does not apply and these emissions were removed from the ca lculations. The additional 600

- ton increase came

### 21 Commenter Comment # Section Comment DEQ Response and gas sources, 7,000 TPY NO x reductions from BART sources, and 50,000 TPY from mobile sources rules which can be counted as “ other requirements of the CAA”. Excluding mobile source emissions, Wyoming has chosen a reasonable progress goal that is a net addition of NO x , which represents “less visibility improvement...”

. from commercial coal, i ndustrial processes, and drill r ig growth. Wyoming does co ntain these

sources , so the 600

- ton increase will remain in the calculations. The appropriate tables have been up dated to reflect these changes.

In terms of the NO x increase, the State is in a difficult position since the Division is hoping to combine efforts for ozone and regional haze as a more efficient strategy and ozone is the driving force in this process.

In terms of the oil and gas increase, DEQ agrees that it is important to recognize and regulate oil and gas emis sions. As outlined in the long

- term strategy portion of the SIP, DEQ cannot complete the evaluation of oil and gas on visibility until Phase III of the WRAP study has been complete d

.

US Forest

Ser vice D52 Chapter 7 The use of a Q/d screening tool for evaluating reasonable progress controls seem s reasonable for large stationary sources. Is Q/d on unit emissions or facility/project emissions? Is it Wyoming’s intent to decrease the Q/d threshold for future planning periods, hence allowing more facilities to be considered? Does Wyoming DEQ have a li st of all considered sources (not just Q/d=10) and the corresponding Q/d? If so, that list should be included in the SIP. How many additional sources would be included if Wyoming applied a Q/d of 9 for example? Wyoming selected Q/d>10 as a screening thres hold based on the Federal Land Manager’s recommendations. When the State used this threshold it was found that all BART sources were captured, and therefore DEQ determined that this was a good place to start . The process is performed on unit emiss ions. The State has not decided that the same screening threshold will be used in subsequent planning periods.

The Division performed calculations to determine what percentage of the total NO x emissions in the State were captured using a threshold of Q/d equal t o 10. This threshold captures nearly 90% of the total emissions in Wyoming. Reducing the threshold to 5 only captures another 5% of the total emissions. Therefore, a Q/d of ten was considered appropriate by the State.

US Forest

Service D53 Chapter 7 The Q/d analysis does not practically address area sources. How will area sources be addressed under reasonable progress? The Q/d analysis addresses all inventoried sources, not just point sources. The analysis uses
WRAP ’ s emissions inventory to identify all sources that have a Q/d greater than ten. In general, area sources did not meet this criterion which is why they were not identified in the analysis. It is important to note that this criterion was used as a starting point for the first planning period. The Division will likely look at using a more refined method in future SIP revisions, which will in turn capture more sources.

### 22 Commenter Comment # Section Comment DEQ Response

US Forest

Service D54 Chapter 7 From the 309(g) Technical Support Document on the Wyoming DEQ website, this table lists sources with Q/d>10. Please add to this table the identification of which sources were controlled, by what technologies, and whether under BART or Reasonable Progress. The table identified by the FS does indicate whether or not the plant is subject to BART (in
pa renthesis under the p lant name). If the source is subject to BART, then controls were applied. A list of the BART controls for each source can be found in Table 6.4

- 1 of the SIP. The remaining sources were identified under reasonable progress for source s that could be controlled as part of the SIP ’s long

- term strategies.

US Forest

Service D55 Section 7.3.3 When citing cost effectiveness value, such as in regard to low

NO x burners with or without overfire air, please reiterate that lower values are considered more favorable. The DEQ believes that the following sentences in Section 7.3.3 imply that lower values are more favorable: “While SCR is expected to be far more efficient in controlling NO x emissions than LNB or LNB w/OFA, the estimated capital and annual costs are far higher than the costs associated with LNB or LNB w/OFA. As shown in Table 7.3.3

- 1, NO x reductions using LN or LNB w/OFA technology are far more cost effective than the SNCR a nd SCR technologies.”

US Forest

Service D56 Section 7.3.5 When will the phase II report be available? WRAP ’ s Phase II report is already available through the following website: http://www.wrapair.org/forums/ogwg/Phases_I_and_II_Inventories.html

According to WRAP ’ s project schedule: http://www.wrapair.org/forums/ogwg/documents/Phase_III_Project_Overview.pdf

The final report for Phase III was scheduled to be released June 2009. The WRAP ran out of funding and Wyoming has recently contributed additional dollars to this effort to complete the task. The DEQ is hopeful that the report will be finalized in the near future.

US Forest

Service D57 Section 7.3.5 Table 7.3.5

- 1 lists 16

- 36 $/ton for SNCR with 90

- 99% efficiency for compressor engines. Why not require this on all units? Oil and gas sources were not addressed in this SIP. The DEQ is waiting for the WRAP Phase III report before it will begin the rulemaking process to control oil and gas sources. However, many compressor engine facilities have already install ed control equipment. For lean burn engines, oxidation catalysts are commonly installed while SNCR catalysts with AFRC are commonly installed for rich burn engines.

### 23 Commenter Comment # Section Comment DEQ Response

US Forest

Service D58 Section 7.6 Neff, et al. 2008 suggests that roughly 75% of windblown dust is attributed to human activity. As such, is it not appropriate to use windblown dust as a reason for failure to achieve the URP? Although windblown dust is an uncontrollable activity, the DEQ does not find it appropriate to include windblown dust as a reason why the Division ’ s Reasonable Progress Goals (RPG) are lower than the Uniform Rate of Progress (URP). It can be seen on the regional haze composition page ( http://vista.cira.colostate.edu/dev/web/AnnualSummaryDev/Composition.aspx ) that the Wyoming Class I areas are dominated by organic carbon and sulfate. Fine soil, including windblown dust
, only makes up between 3

- 7% of the total composition on the 20% wo rst days. In all monitor locations the fine soil either meets the URP goal or falls just short of achieving it (0.1 Mm

- 1 below).

US Forest

Service D59 Section 7.6 While it is true that Western Class I areas are cleaner than their Eastern counterparts that can make it less difficult to show improvements. That is, cleaner air is more sensitive to changes in pollution. This is why it is important to consider visibility impacts (e.g. $/dv) when determining control strategies. It is true that cleaner air is mor e sensitive to changes in pollution , and wildfires within th e Western states have caused Western states to be unable to meet the URP goals.
EPA’s Appendix Y BART guidance does mention that “dollars per deciview” ($/dv) is a metric that could be used to e valuate the cost of BART compliance, but by no means identifies $/dv as an essential or required metric. The Division considered capital cost, annual cost, cost effectiveness, and incremental cost effectiveness in the cost evaluation of each proposed BART control option. The Division chose not to use a hybrid metric such as $/dv primarily because of the lack of historical precedent regarding reasonable/acceptable levels for such a metric. Additionally, the use of a hybrid cost metric such as $/deciview c an introduce uncertainty as to how the value was calculated. The value of “/deciview” could be based on the highest modeled value in a given area or the 98th percentile modeled value. It could be based on the 98th percentile value for any one modeled yea r or it could be an average for multiple years. It could even be based on an average modeled value across an entire Class I area or the sum of deciview changes across multiple areas. The Division has found that $/dv values are often presented without exp lanation of the basis for the calculation. To avoid these confounding factors, the Division chose to evaluate and present the cost analyses and visibility analyses separately.

US Forest

Service D60 Section 7.6 Section 7.6 lists many reasons why Wyoming considers its RP goals to be reasonable, however none appear to be related to the four factors in 40 CFR 51.308(d)(1)(i)(A), which are The State has provided a four

- factor analysis for all qualifying sources. The Division believes that it has adequately identified the State’s inability to install the control technology within the first planning period under the Time Necessary for Complia nce sections. 40 CFR

### 24 Commenter Comment # Section Comment DEQ Response required to be considered in making the determination of RP goals below the UR P. In absence of the four

- factor demonstration referred to above, the FS concludes that Wyoming’s proposed RP goals are not sufficiently justified. 51.308(d)(1)(i)(A) indicates that the State must “ include a demonstration showing how these factors were taken into consideration in selecting the goal” . Although the four

- factor analysis was not outlined as a reason why URP goals co uld not be achieved, Section 7.5 outlines how the results were used to develop the RPGs, satisfying 51.308(d)(1)(i)(A).

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Service D61 Chapter 8 While T able s 8.1.2.1

- 1 and 8.1.2.1

- 2 do an adequate job of demonstrating impacts from Wyoming emissions o n surround ing States’ Class I areas, documentation of the projected impacts from Wyoming emissions on surrounding States’ Class I areas in the future is left in the 309(g) Technical Support Document. All discussions belong in the SIP as part of the RP dem onstration. The DEQ believes that the SIP does an adequate job of demonstrating impacts from Wy oming emissions on surrounding s tates. As participating members of the WRAP, the State has ongoing discussions with other s tates regarding Wyoming’s contributio ns to out of state C lass I

areas. The Division bel ieves it is appropriate to list these discussions in the Technical Support
Document.

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Service D62 Chapter 8 The comment that impacts from Wyoming emissions are “a small portion of out

- of

- state visibility degradation” is subjective and perhaps misleading. The impacts are averaged over many days, and the maximum daily contributions could be much higher. Projections of future increases in Wyoming
NO x impacts could significantly increase Wyoming’s share of impacts even as surrounding States try to meet their reasonable progress goals. Page 130: “By 2018, NO x emissions from Wyoming are projected by the WRAP to decrease by 39,861 tons, which will help reduce Wyoming’s impact to out of state Class I areas”. While these emissions should decrease impacts on average, localized emissions increases could clearly cause some Class I area impacts to increase. DEQ believes it is appropriate to average impacts over many days, rather than look at each day individually. While it is true that episodes may increase the impacts from Wyoming on some days, it is also true that on other days the impacts will be much lower. For this reason, an average is used to account for the highs and lows. The State’s overall goal is to decrease haze causing emissions to a level that allows the achievement of natural visibility conditions by 2064. A decrease of 39,861 tons of NO x by 2018 will help achieve this goal. Although the overall impacts on Class I areas outside of Wy oming should decrease due to this NO x reduction, there may be some areas that do not experience as strong of an impact reduction. Growth factors have been applied to the WRAP emissions inventory to account for industrial growth. Depending on the proximit y of out of state Class I areas to areas of growth, there are some areas that will experience an increase in NO x emissions. The State has and will comply in the future with 40 CFR 51.308(d)((3)(ii): “ If the State has participated in a regional planning
pr ocess, the State must ensure it has included all measures needed to achieve its apportionment of emission reduction obligations agreed upon through that process”.
W yoming’s contribution to other state s ’ visibility impairment has been addressed with the
ap propriate states. The consultation process can be found in Chapter 11 of the SIP and also Chapter 11 of the Technical Support Document (TSD)

.

### 25 Commenter Comment # Section Comment DEQ Response

US Forest

Service D63 Chapter 8 What is the final proposal for RP controls at Laramie Cement Plant? What are the actual NO x emissions at Laramie Cement Plant? Are they 524 TPY 9 Table 4.1 EC/R report) or 2080 TPY (Table 7

- 1 EC/R general report)? The four

- factor analysis was performed on the Laramie Cement Plant to identify potential control devices. Since the State does not have the autho rity to regulate this source for purposes of meeting regional haze goals , a final control device has not yet been proposed. It is unfortunate that the EC/R reports are not consistent. However , this report has been finalized by EC/ R Incorporated. If there is an opportunity for the State to comment at a later date, this comment will be included.

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Service D64 Chapter 8 The FS supports the decisions for SCR at the Laramie River and Jim Bridger Power Plants. The DEQ appreciates FS support for the decisions made in the long

- term strategy. However , the Laramie River Station does not require SCR. The facility appealed the BART permit before the Environmental Quality Council (EQC), and a settlement was reached. The res ulting requirement is that the Laramie River Station shall further reduce the NO x emissions from Units 1, 2, and 3 to a plant

- wide emission limit of 12,773 tons of NO x per year by December 31, 2017 and continuing thereafter, unless this changes pursuant to new regulatory or permit requirements. The new Laramie River conditions allow for greater reductions to occur within the first regional haze planning period. All reductions for the unit s will occur by 2017, rather than 2023.

US Forest

Service D65 Section 8.2.1.6 Manufacturers are supposed to begin producing tier/transitional heavy

- duty engines in the period 2011

- 2014 and tier 4 /final engines beginning in 2015. Since these changes will occur in the planning period, they should be acknowledged in the SIP. I t is true that manu facturers will begin producing t ier IV engines and making them available to sources. However, there is not a federal or State standard or rule in place that will require sources to use these engines. The Regional Haze SIP can only cont ain enforceable measures
, and at this time, the use of t ier IV engines is not enforceable. Although there are not any standards or rules in place that require sources to use tier IV engines, the New Source Review (NSR) program requires facilities to analy ze the Best Available Control Technology. Therefore, if tier IV engines are the best available control technology at the time of permitting, they will be captured through the NSR program.

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Service D66 Section 8.2.1.7.2 As of 2007, EPA’s natural events policy of 1996 has been superseded by an exceptional events rule under 40 CFR 50.13. The rule covers all areas in Wyoming, not just the PRB. The Division recognizes that EPA’s Natural Events Policy has been superseded by the Exceptional Events Rule . Since rule revision is currently being considered by EPA, the State has decided to revise this section in the next planning period.

### 26 Commenter Comment # Section Comment DEQ Response

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Service D67 Section 8.3.4 Wyoming states that RP rulemaking will be co mpleted by 2013. The FS believes that Wyoming has not demonstrated that it is meeting its share of emissions reductions for Class I areas inside and possibly outside of Wyoming. The WRAP commissioned reports with supplementary information for “four factor analyses” for a variety of sour ce categories. Many of these analyses suggest low cost controls for source categories with significant emissions. Why is this information not mentioned or incorporated in the current SIP draft (other than as addendums in the TSD)? Section 8.3.4 has been revised, and the commitment to complete rulemaking by 2013 has been removed. The WRAP supplementary reports were considered in the SIP. There were two four

factor analyses documents referenced in the SIP that were prepared by WRAP; one for all participa ting WRAP states and one for only Wyoming. The first document con tains all of the sources in the participating states that w ere identified through the four

- factor analysis. The Wyoming

- spec ific report summarizes the four

- factor analyses that were performed on sources within Wyoming. There were only two Wyoming sources that were identified under the four

factor analysis: PacifiCorp Dave Johns t on Electric Generating Station, and Mountain Cement
C ompany Laramie Plant. The four

- factor analysis was included in the SIP in Sections 7.3.3 and
7.3.4.

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Service D68 Chapter 9 FS notes that Wyoming operates IMPROVE protocol samplers at Thunder Basin National Grasslands and Cloud Peak Wilderness. FS finds this information useful and wishes to acknowledge Wyoming’s efforts. The FS also acknowledges the support we receive from Wyoming in providing a site operator at the North Absaroka IMPROVE site. Wyoming’s cooperation in visibility monitoring is greatly appreciated. DEQ appreciates the acknow ledgement of the Division ’ s visibility monitoring efforts.

US Forest

Service D69 Section 5.2.9 Should “fine PM” be “fine soil” ? Fine PM was used to include all fine PM sour ces such as those from industrial sources , not just fine soil.

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Service D70 Table 7.3.4

- 1 Are the cost effectiveness values for selective non

- catalytic reduction with urea and ammonia correct? This table was developed by EC/R Incorporated. The report includes references for all of the values used in the tables: http://deq.state.wy.us/aqd/308%20SIP/EC

R%20Four%20Factor%20Analysis%20WY_final050609_Chap.%207.pdf

.

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Service D71 Table 7.3.4

- 2 Column 3 Potential Emission Reduction (1000 tons/yr) should be TPY

. TPY is an abbreviation of tons/yr, and carries the same meaning.

### 27 Commenter Comment # Section Comment DEQ Response

US Forest

Service D72 Page 167 “In spite of the large number of growing uncontrollable sources in the WRAP region, however, Wyoming does not see a net visibility improvement at the Wyoming Class I areas through 2018.” Should read “uncontrollable sources impacting the WRAP region...” The DEQ cannot find this reference in the revised SIP. Please provide a section number where this error can be found.

US Forest

Service D73 Section 7.3.5 Please correct the typo on the acronym for air

- fuel ratio controls (AFRC). This has been corrected in the SIP.

US Forest

Service D74 Chapter 8 In the last sentence under the Bridger

- Fitzpatrick nitrate section, please revise the phrase “of at least 39861 tons” to “by at least 39,861 tons”. This wording has been changed in the SIP.

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Service D75 Dispersion Modeling The FS is concerned that visibility impacts may be underestimated in the refined modeling, as caused by an under

- representation of the ozone concentrations. The ozone data used in the BART modeling is not believed to be spatially or temporally representative of the ozone concentration of the plume/puff traveling from any of the BART

- e ligible emission sources near Green River toward the Fitzpatrick and Bridger Wilderness areas. The ozone data used in the modeling is from 2001 through 2003. The emissions must pass through the atmosphere near the Jonah and Wamsutter fields, and by 2006 the producing wells increased dramatically, and the first ever winter ozone exceedance was experienced. Similarly, the spatial distribution of the ozone monitoring sites used in the BART modeling analysis is suspect. To remedy this issue, the FS is reque sting that Wyoming DEQ re

- evaluate the more recent hourly ozone data to ensure an appropriately representative value is used, and rerun the BART dispersion modeling analysis. The AQD believes the background ozone concentrations used in the BART modeling we re both temporally and spatially representative. The commenter provides two examples relative to their claim that the background ozone data are not temporally representative . For one, they cite the increase in oil and gas wells producing in Wyoming from the time period used in the modeling (2001

- 03) to 2006. Secondly, they cite the wintertime exceedances of the ozone standard that were first measured in Sublette County in 2006. Regarding the first example, t he
Division has calculated annual average ozon e concentrations for recent years (2007

- 2008 , and part of 2009 ) fr om many of the ozone monitoring stations within the modeling domain, including Thunder Basin, Jonah, Rocky Mountain National Park, Centennial, and Pinedale. Annual average values for these stations ranged from 35 ppb to 49 ppb. The data from the seven ozone monitoring stations used in the 2001

- 03 BART modeling showed a range of annual averages of 38 ppb to 55 ppb, which suggests the data used in the modeling is temporally representative. R egarding the exceedances of the ozone standard in Sublette County, it is important to note that this phenomenon occurs over a very limited geographical area under a specific set of meteorological conditions. These ideal conditions occur temporarily during a limited number of weeks in the late winter and early spring, if at all during a given year.

The AQD also believes that the ozone data used for the BART modeling were spatially representative. Data from seven ozone monitoring stations located througho ut the modeling

### 28 Commenter Comment # Section Comment DEQ Response domain were input to the model (CALPUFF), and the model accounts for background ozone for each grid cell on the domain by using data from the nearest monitor.

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Service D76 Natural Background Concentrations The DEQ states that “Species concentrations corresponding to the 20 percent best days were c alculated for each Class I area by scaling back the annual average concentrations given in Table 2

- 1 of the EPA document Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule.” Additional information is needed to understand and evaluate the use of scaling factors as applied to the annual average concentrations for calculating background concentrations for the 20 percent best days. Individual s pecies concent rations corresponding to the 20% best days natural background were calculated for each Class I area by scaling back the annual average natural background concentrations given in Table 2

- 1 of the EPA document Guidance for Estimating Natural Visibility Condi tions Under the Regional Haze Rule. The EPA guidance document provides annual average values of natural background for individual species, and total deciview values for the 20% best days for particular areas, but does not provide values for individual spe cies for the 20% best days. Therefore, the Division developed separate scaling factors for each Class I area such that, when multiplied by the guidance table annual concentrations for each species, the 20% best days concentrations for each species for tha t particular Cl ass I area could be calculated.

The scaling procedure is illustrated here for Bridger WA. From Appendix B in the EPA natural visibility guidance document, the total deciview value for the 20 % best days at Bridger WA is 1.96 dv. To obtain the speciated background concentrations representative of the 20 % best days, the deciview value (1.96 dv) was first converted to light extinction. The relationship between deciviews and light extinction is e xpressed as follows :
dv = 10 ln (b ext /10) or b ext = 10 exp (dv/10)

where: b ext = light extinction expressed in inverse megameters (Mm

- 1 )

Using this relationship with the known deciview value of 1.96, one obtains a n equivalent light extinction value of 12.17 Mm

- 1

. Next, the annual average natural visibility concentrations

were set equal to a total extinction value of 12.17 Mm

- 1 . The relationship between total light extinction and the individual components of the light extinction is as follows:

b ext = ( 3)f(RH)[ammonium sulfate] + (3)f(RH)[ammonium nitrate] + (0.6)[coarse mass] + (4)[organic carbon] + (1)[soil] + (10)[elemental carbon] + b ray

where:

### 29 Commenter Comment # Section Comment DEQ Response

• bracketed quantities represent background concentrations in μg/m 3

• values in parenthesis represent scatterin g efficiencies

• f(RH) is the relative humidity adjustment factor (applied to hygroscopic species only)

• b ray is light extinction due to Rayleigh scattering (10 Mm

- 1 used for all Class I areas)

Substituting the total light extinction for the 20% best days, t he annual average natural background concentrations, the average f(RH) for Bridger WA, and including a coefficient for scaling, one obtains :
12.17 = (3)(2.1)[0.12]X + (3)(2.1)[0.1]X + (0.6)[3.0]X + (4)[0.47]X + (1)[0.5]X + (10)[0.02]X + 10

In the equation above, X represents a scaling factor needed to convert the annual average natural background concentrations to values representative of the 20 % best days natural background . Solving for X provides a value of 0.376.

Because of the geographical proximity and similar annual background visibility for the Bridger WA and Fitzpatrick WA, the scaled aerosol concentrations for the two areas were averaged.

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Service D77 FMC Granger BART T he FS understands that two BART

- eligible units were evaluated and deemed exempt from BART based o n refined dispersion modeling at the FMC Granger plant; two coal

- fired boilers each equipped with FGD scrubber and EPS controls. Given the modeling concerns expressed, the FS cannot concur that these units are not subject to BART at this time. As indicated in the above comments, the DEQ is confident in the modeling approach taken to evaluate the FMC Granger BART sources. The State used a 0.5 dv threshold level to exempt a source from BART or to deem the modeled impacts as in significant. The Division is comfortable with this threshold level. EPA’s Regional Haze Regulations and Guidelines for Best Available Retrofit Technology (BART) Determinations (Appendix Y to 40 CFR part 51), suggest that 0.5 dv can represent the level at which a source “contributes” to visibility impairment. This is also consistent with the rules which are being applied by most states in the WRAP region , including the State of Wyoming (Chapter 6, Section 9), WAQSR . Further, the Division believes that th e 0.5 deciview threshold is a conservative value given that language in the Regional Haze Rule suggests that 1.0 dv is an appropriate perceptibility threshold and recent literature suggests that the perceptibility threshold is great er than 1.0 dv (from pag e 39120 of Appendix Y to 40 CFR part 51).

### 30 Commenter Comment # Section Comment DEQ Response

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Service D78 FMC Westvaco The FS acknowledges the approach taken by the DEQ for the BART determination for the Westvaco facility. However, recognizing that BART is one of three components of the Regional Haze Rule that the State will use to achieve our natural visibility goals, we encourage the DEQ to consider the

cum ulative impacts of several BART

- eligible sources in the Green River area. The general comments regarding the dispersion modeling apply to t his facility, and if the impacts are underestimated, it would warrant further emission reductions. The costs for implementing controls beyond the minimum proposed by the DEQ are reasonable. Additional controls implemented at this time will help the DEQ m ove closer toward its reasonable progress goals. As stated in the above responses, the DEQ is confident in the modeling approach taken to estimate impacts from BART sources, and does not believe the impacts to be underestimated. The DEQ does not agree tha t facilities identified by the FS should be grouped together, and cumulative impacts considered. Summing the 98th percentile modeled visibility impacts for separate facilities is not an accurate portrayal of combined impacts because the individual impacts may occur at different locations (receptors) and during different 24

- hour time periods. Moreover, the visibility impacts from BART

- eligible sources are to be determined separately. As stated in the EPA’s Appendix Y to part 40 CFR 51

- Guidelines for BAR T Determinations Under the Regional Haze Rule, relative to the use of the CALPUFF model for BART determinations, “We believe that CALPUFF is an appropriate application for States to use for the particular purposes of this rule, to determine if an individua l source is reasonably anticipated to cause or contribute to impairment of visibility in Class I areas, and to predict the degree of visibility improvement which could reasonably be anticipated to result from the use of retrofit technology at an individual source. We encourage States to use it for these purposes.”

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Service D79 FMC Westvaco: SO 2 Controls The SO 2 controls identified for the two coal

- fired boilers are limited to two options f or increasing the amount of gas

- routed exhaust through the wet scrubber. The EPA BART rule identifies several other wet scrubber upgrade options such as: installation of liquid distribution rings, installation of perforated trays, use of organic acid additives, improve or upgrade scrubb er auxiliary system equipment, and redesign spray header of nozzle configuration. Each of these options should be considered in the BART analysis. Wyoming is a §309 state and will participate in the Western Backstop Sulfur Dioxide Trading Program , should it be triggered. §308(e)(2) provides States with the option to implement or require participation in an emissions trading program or other alternative measure rather than requir ing sources subject to BART to install, operate, and maintain additional cont rol technology to meet an established emission limit. In their BART application, FMC presented information relative to several preferred options for SO 2 control. Consideration of an exhaustive list of SO 2 control methods would be immaterial given Wyoming ’s status as a §309
state.

### 31 Commenter Comment # Section Comment DEQ Response

US Forest

Service D80 FMC Westvaco:

Visibility Modeling It would be helpful if the modeling results were presented for a combination of LNB/OFA/SNCR (NO x ) and scrubber upgrades, both with and without a new bypass (SO 2 )

. Visibility modeling was conducted for six control options, including LNB/OFA/SNCR with baseline SO 2 , and baseline NO x with scrubber upgrades/new bypass. The 98 th percentile results for all of the control scenarios for each of the two FMC Westvaco boilers were less t han the 0.5 dv threshold used to deem modeled impacts as insignificant , and provided the AQD adequate information to determine BART relative to the fifth statutory factor (visibility improvement).

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Service D81 FMC Westvaco: BART Determination The BART determination is based upon considerations of the model

- predicted change in deciviews compared to baseline conditions. EPA states in the preamble of its BART Guideline that “Even though visibility improvements from an individual source may not be per ceptible, it should still be considered in setting BART because the contribution to haze may be significant relative to other source contribution in the Class I areas.” Given the proximity of the two boilers, the combined effect of requiring more stringen t controls, such as LNB/OFA with SNCR, will likely allow the State to reach its reasonable progress goals. The AQD determined the visibility impacts from BART

- eligible sources separately. As stated in the EPA’s Appendix Y to part 40 CFR 51

- Guidelines fo r BART Determinations Under the Regional Haze Rule , relative to the use of the CALPUFF model for BART determinations, “ We believe that CALPUFF is an appropriate application for States to use for the particular purposes of this rule, to determine if an indi vidual source is reasonably anticipated to cause or contribute to impairment of visibility in Class I areas, and to predict the degree of visibility improvement which could reasonably be anticipated to result from the use of retrofit technology at an indiv idual source. We encourage States to use it for these purposes .”

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Service D82 General Chemical Green River Works: Effectiveness

of Control Technologies: NO x In its preamble to its BART Guidelines, EPA states “ Many control techniques....can perform at a wide range of levels...It is important however, that in analyzing the technology, you take into account the most stringent emission control level that the technology is capable of achieving”. The FS states what DEQ identified as achievable NO x control limits, and what can be achieved by other facilities with the same controls. The FS believes that the DEQ should analyze more stringent control levels. The use of lower than best available control technologies results in lower model

- predicted reductions in haze, and therefore potentially affects the determinations of
BART. The initial BART determination for the two boilers at the Green River Works called for LNB with existing OFA systems and a NO x emission limit of 0.32 lb/MMBtu. Based on new engineering information that indicated the emission limit of 0.32 lb/MMBtu would not be achievable using LNB with existing OFA systems, General Chemical has applied for a revised BART permit that would include LNB with new separated overfire air (SOFA) and NO x emissi on limits of 0.28 lb/MMBtu. The NO x emission limit of 0.28 lb/MMBtu would represent emissions reductions of more than 40% as compared to baseline.

The control efficiencies and emissions used by the AQD for the BART modeling resulted in predicted visibility impacts below 0.5 Δdv for all of the control options

. The use of even lower emission rates would not have changed the AQD’s BART determination relative to the modeled visibility impacts.

### 32 Commenter Comment # Section Comment DEQ Response

US Forest

Service D83 General Chemical Green River Works: Costs The costs for applying each control technology in the Green River Works plant are higher than typical cost ranges. Costs presented by the BART applicant, as described in the BART application document, were developed using budgetary quotes from equipment vendors and methods from the EPA’s Control Cost Manual . All costs were scrutinized by AQD permit engineers as part of the permit application review process, and the AQD believes the presented costs were reasonable.

US Fore st

Service D84 General Chemical Green River Works: Western Backstop Sulfur Dioxide Trading Program The DEQ has stated that “General Chemical will not be required to meet either proposed emission limit under BART. Instead
, General Chemical will be required to participate in the emissions trading program under Chapter 14 of the WAQSR should the program be triggered”. The FS requests additional information to support that greater re asonable progress will be in the Fitzpatrick and Bridger Wilderness Areas throug h the milestones program

. The Division has demonstrated the superiority of the 309 program in the Demonstration that the SO 2 Milestones Provide Greater Reasonable Progress than BART d ocument in Appendix E

. In this demonstration, the S tate not only verifies that the program meets or exceeds presumptive SO 2 BAR T levels, but also provides other benefits of implementing the milestone program. One of these benefits includes limiting new source growth for SO 2 emissions in the participating states. In ad dition, the program includes every source that emits 100 tons per year or greater of SO 2 , and therefore targets a greater number of sources than what would be identified in the BART program. Table 6.2.2 of the SIP demonstrates visibility improvement on th e worst days and no degradation of visibility, and in many cases improvement, on the best days for all Wyoming Class I areas and Class I areas in surrounding states. The DEQ believes that the better than BART determi nation is adequate and the BART

- eligibl e sources are not required to achieve the limits established under BART.

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Service D85 General Upon review of the five statutory factors, the FS believes that selective catalytic reduction (SCR) sh ould be BART for nitrogen oxides (NO x ) for all units in both the Jim Bridger and Naughton power plants. The FS applauds the State of Wyoming for proposing to install SCR at the four units at the Jim Bridger EGU, but believes the installation timeframe should be within
2015

- 2016 timeframe for all four units at the facility. The Division determined BART for NO x control at the Jim Bridger and Naughton power plants based on consideration of all five statutory BART factors, as required by EPA’s Appendix Y BART guidance. No single factor was weighted as being mor e important than another, because the Division looked at all five statutory factors in their entirety. The BART determination for NO x control on all four units at Jim Bridger included low NO x burners (LNB) with overfire air (OFA). The BART determinations for NO x control at Naughton included LNB/OFA on Units 1 and 2 and SCR on Unit 3. The Division’s BART analyses provide the basis for the BART determination for both plants

. Regarding the installation of additional control equipment at the Jim Bridger plan t, PacifiCorp is required by the BART permit to install SCR on Jim Bridger Unit 3 in 2015 and Jim Bridger Unit 4 in 2016 as well as add

- on NO x control on Units 1 and 2 no later than 2023. The schedule for installation is based on the incorporation of SCR add

- on control on these units under the long

term strategy component of Wyoming’s SIP for regional haze as well as PacifiCorp’s

### 33 Commenter Comment # Section Comment DEQ Response
construction p lan for pollution control projects. The schedule for the installation of SCR controls at other plants is uncertain at this point due to the demands on PacifiCorp for compliance with BART and other regulatory programs. PacifiCorp operates 19 coal

- fired un its, 14 of which are BART

- eligible. Additional BART

- eligible units are owned or partly owned in Arizona, Colorado, and Montana.

The BART permits for the Jim Bridger plant are currently under appeal with the Environmental Quality Council.

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Serv ice D86 BART: Jim Bridger and Naughton The FS commends PacifiCorp and Wyoming DEQ for the strong
NO x controls proposed for BART and reasonable progress. The FS believes the proposed controls will significantly improve air quality in the many Class I areas surrounding the facilities. While the FS does not agree with every conclusion, the BART documents are thorough and well written. DEQ appreciates the FS recognition of the air quality improvements that will occur due to the BART controls.

US Forest

Servic e D87 BART: Jim Bridger and Naughton The FS believes that the cost of each BART alternative should be divided by the sum of the deciviews improvement at all impacted Class I areas to determine the cost per deciviews. This may results in acceptance of previously discarded control alternative s due to the showing of reasonable cost of visibility improvement. EPA’s Appendix Y BART guidance does mention that “dollars per deciview” ($/dv) is a metric that could be used to evaluate the cost of BART compliance , but by no means identifies $/dv as an essential or required metric. The Division considered capital cost, annual cost, cost effectiveness, and incremental cost effectiveness in the cost evaluation of each proposed BART control option. The Division chos e not to use a hybrid metric such as $/dv primarily because of the lack of historical precedent regarding reasonable/acceptable levels for such a metric. Additionally, the use of a hybrid cost metric such as $/deciview can introduce uncertainty as to how the value was calculated. The value of “/deciview” could be based on the highest modeled value in a given area or the 98th percentile modeled value. It could be based on the 98th percentile value for any one modeled year or it could be an average for mul tiple years. It could even be based on an average modeled value across an entire Class I area or the sum of deciview changes across multiple areas. The Division has found that $/dv values are often presented without explanation of the basis for the calcu lation. To avoid these confounding factors, the Division chose to evaluate and present the cost analyses and visibility analyses separately.

### 34 Commenter Comment # Section Comment DEQ Response

US Forest

Service D88 BART: Jim Bridger and Naughton The FS would like to see visibility modeling for all Class I areas within 300 km. If any modeling already exists that shows visibility improvement benefits greater than 0.5 dv beyond 300 km, the FS requests that information be included as well. Only those Class I areas most likely to be impacted by sources subject to BART at a given facility were modeled, as determined by source/Class I area locations, distances to each Class I area, and professional judgment considering meteorological and terrain factors. The Division recognizes that more distant Class I areas may yield modeled impacts of some magnitude, but the Division is also satisfied that Class I areas at a greater distance and in directions of less frequent plume transport would not yield modeled impacts greater than those yielded by the Class I areas chosen for BART modeling. The modeling results for the Class I areas chosen for analysis allowed the Division to make an informed decision on the effect on visibility from the various BART control options. Additionally, EPA’s Appendix Y BART guidance does not i nclude any requirements for modeling distance

.

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Service D89 BART: Jim Bridger and Naughton The State of Wyoming has determined that the Savage Run Wilderness Area will be managed as a Class I airshed. Therefore, the FS would like Savage Run Wilderness Area to be treated as such in all Regional Haze planning including this
BART review. EPA’s Regional Haze Rule affects sources that may cause or contribute to visibility impairment
at any mandatory, federal Class I area. Because Savage Run is a S tate

- designated Class I area, the Division was not required to include it in the BART modeling. Additionally, the Division did not include Savage Run in any of its analyses for the State’s Regional Haze Visibility SIP. For BART, the Division did model t he impacts at several mandatory Class I areas that are located in the same general plume transport direction downwind of Savage Run, including Mt. Zirkel Wilderness, Rawah Wilderness, and Rocky Mountain National Park. Based on the mode ling results for the se Class I a reas in the proximity of Savage Run, the Division anticipates similar improvements in visibility from the analyzed emission reductions

.

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Service D90 BART: Jim Bridger and Naughton Pa ges E2

- 5 and 5

- 10 of the PacifiC orp BART analysis discuss

“ Just

- noticeable difference in atmospheric haze” indicating that minimal, if any observable visibility improvements at the Class I areas would be expected under any of the control scenarios. It is incorrect to dismiss a control strategy on the bas is that the resulting improvement is not perceptible or significant. The Division used 0.5 dv as the threshold level to exempt a source from BART or to deem modeled impacts as insignificant. EPA’s Regional Haze Regulations and Guidelines for Best Availabl e Retrofit Technology (BART) Determinations (Appendix Y to 40 CFR part 51), suggest that 0.5 dv can represent the level at which a source “contributes” to visibility impairment. This is also consistent with the rules which are being applied by most states in the Western Regional Air Partnership (WRAP) region

.

US Forest

Service D91 BART: Jim Bridger and Naughton EPA’s view of presumptive limits for SO 2 and NO x for EGUs are that they are “ highly cost effective” . So although the presumptive requirements are “ extremely likely to be Although the BART emission limits for NO x for Naughton Units 1 and 2 exceed the presumptive BART limit for tange ntial

- fired boilers burning sub bituminous coal, PacifiCorp’s analysis of coal composition was not a factor in the Division’s determination. The Division established NO x

### 35 Commenter Comment # Section Comment DEQ Response appropriate” the State can demonstrate otherwise based on the five statutory factors. The FS believes that the analysis of coal composition is not only flawed in its conclusions, more principally, it does not meet the requirement fo r a demonstration of why presumptive limits cannot be reached. emission limits for BART at the Naughton plant based on consideration of all five statutory factors, as required by EPA’s Appendix Y BART guidance. The Division in terpreted the presumptive emission levels for NO x and SO 2 as recommended control levels proposed by EPA after reviewing technical data related to BART. Requiring sources to meet presumptive emission levels was not required as one of the five statutory fac tors. Conversely, the Division did not automatically determine emission levels below presumptive levels to be BART, but considered all five statutory factors before making a BART determination

.

US Forest

Service D92 BART: Jim Bridger and Naughton The FS believes that SCR is BART for all units at Jim Bridger and Naughton power plants

. The Division determined BART for NO x control at the Jim Bridger and Naughton power plants based on consideration of all five statutory BART factors, as required by EPA ’s Appendix Y BART guidance. No single factor was weighted as being more important than another, because the Division looked at all five statutory factors in their entirety. The BART determination for NO x control on all four units at Jim Bridger included low NO x burners (LNB) with overfire air (OFA). The BART determinations for NO x control at Naughton included LNB/OFA on Units 1 and 2 and SCR on Unit 3. The Division’s BART analyses provide the basis for the BART determination for both plants

. Regarding the installation of additional control equipment at the Jim Bridger plant, PacifiCorp is required by the BART permit to install SCR on Jim Bridger Unit 3 in 2015 and Jim Bridger Unit 4 in 2016 as well as add

- on NO x control on Units 1 and 2 no later than 20 23. The schedule for installation is based on the incorporation of SCR add

- on control on these units under the long

term strategy component of Wyoming’s SIP for regional haze as well as PacifiCorp’s construction plan for pollution control projects. The s chedule for the installation of SCR controls at other plants is uncertain at this point due to the demands on PacifiCorp for compliance with BART and other regulatory programs. PacifiCorp operates 19 coal

- fired units, 14 of which are BART

- eligible. Addit ional BART

- eligible units are owned or partly owned in Arizona, Colorado, and Montana.

The BART permits for the Jim Bridger plant are currently under appeal with the Environmental Quality Council.

### 36 Commenter Comment # Section Comment DEQ Response

US Forest

Service D93 BART: Jim Bridger and Naughton Greater SCR efficiencies that can be achieved by modern NO x control systems should be factored into the cost and visibility analyses. The Division conducted a search of the EPA RACT/BACT/LAER Clearinghouse (RBLC) to find NO x emission limits as BACT associa ted with SCR control in recently issued permits. Two plants have limits of 0.05 lb/MMBtu NO x with a 12

- month rolling average, which is significantly longer than a 30

- day averaging period. Because the 0.05 lb/MMBtu limits are based on a 12

- month averaging period, they are not comparable to the 30

- day limits established by the Division. The two plants with 30

- day averaging periods will be subjected to either a 0.08 lb/MMBtu or 0.07 lb/MMBtu limit, and the limits established by the Division meet these lower limits. A spreadsheet compiled by the National Park Service with a summary of nationwide BART determinations shows that both units outside of Wyoming for which SCR is proposed as BART will be subject to a NO x emission limit of 0.07 lb/MMBtu, and both wil l be based on a 30

- day averaging period

. The RBLC search showed two plants that will be subject to 24

- hour NO x limits of less than 0.07 lb/MMBtu (0.067 lb/MMBtu), but these limits are for newly constructed plants which have been engineered to meet these le vels. BART will require the retrofit of significant controls at plants that were not designed to meet these lower levels. Based on the Division’s evaluation, the Division is satisfied that the NO x emission limit of 0.07 lb/MMBtu (30

- day rolling average) that was evaluated for SCR control under BART is the most stringent control level likely to be achieved in a retrofit

.

US Forest

Service D94 BART: Jim Bridger and Naughton The FS requests clarification as to why units 1 & 2 at the Naughton Power plant are not required to install SCR as part of reasonable progress like the other five units. Based on the cost of compliance and visibility improvement presented by PacifiCorp in the BART applications for Naughton Units 1 and 2 and taking into co nsideration the logistical challenge of managing multiple pollution control installations within the regulatory time allotted for installation of BART by the Regional Haze Rule, the Division did not require additional controls under the Long

- Term Strategy for this SIP. These two units are the smallest of PacifiCorp’s units, and since the Division had to prioritize target emission reduction sources, these two units were left to the next planning period. The State is committed to analyzing additional contro ls for Naughton Units 1 and 2 in the next planning period.

US Forest

Service D95 BART: Jim Bridger and Naughton The FS believes that the already

- permitted installation of wet FGD equipment of the Jim Bridger Power Plant units 1

- 4 should be considered BART. Similarly, the FS believes that the WFGD upgrades have already been (or are scheduled to be) installed on all units at the Jim Bridger plant . For the Naughton plant, W FGD is scheduled to be installed on Units 1 and 2 and WFGD is scheduled to be upgraded for Unit 3. BART limits for SO 2 will not be set because

### 37 Commenter Comment # Section Comment DEQ Response installation of wet FGD equipment for the Naughton Power Plant units 1

- 3 s hould be considered BART. Wyoming is a §309 state participat ing in the Regional SO 2 Milestone and Backstop Trading Program . §308(e)(2) provides s tates within the Transport Region addressed by the Grand Canyon Visibility Transport Commi ssion with the option to implement or require participation in an emissions trading program or other alternative measure rather than to require sources subject to BART to install, operate, and maintain additional control technology to meet an established e mission limit on a continuous basis

.

US Forest

Service D96 BART: Jim Bridger and Naughton There appears to be an error in the analysis for unit 3 at Naughton. The performance of the wet FGD was stated to be 0.10 lb/MMBtu (Table 18) but the cost effectiveness analysis is based on 0.15 lb/MMBtu (Table 24)

. The application of wet FGD on Unit 3 is anticipated to lower SO 2 emissions to 0.10 lb/MMBtu, based on an average coal sulfur content of 0.58% by weight , and to 0.15 lb/MMBtu, based on
an average coal sulfur content of 1.02% by weight. Because both low sulfur and high sulfur coals are used to fuel the boilers at Naughton, 0.15 lb/MMBtu was used as the basis for cost effectiveness. The cost effectiveness is not relevant because BART limits for SO 2 will not be set.
W yoming is a §309 state participat ing in the Regional SO 2 Milestone and Backstop Trading Program . §308(e)(2) provides s tates with the option to implement or require participation in an emissions trading program or other alternative measure rather than to require sources subject to BART to install, operate, and maintain additional control technology to meet an established emission limit on a continuous basis

.

US Forest

Service D97 BART: Jim Bridger and Naughton The FS would like to know if the controls in place at the Naughton and Jim Bridger Power Plants are at least equivalent to the control scenario used in the demonstration report. The State of Wyoming submitted a 309 SIP as is allowed by the Regional Haze Rule. The demonstratio n is regional , and a unit

- by

- unit analysis is not required. It is not required by the Regional Haze Rul e that the State perform source

- specific BART analyses to determine that the 309 program has achieved better than BART reductions. EPA clearly explains the intent for the Rule in the Federal Register, Volume 71, No. 198, Dated October 13, 2006 / Rules and Regulations, in the second paragraph on page 60615: “ As discussed in more detail below, today’s rule also makes clear that where a trading program or o ther similar alternative program has been designed primarily to meet a Federal or State requirement other than BART, the State can use a more simplified approach to demonstrating that the alternative program will make greater reasonable progress than BART. ” The following statement is also made in the same Federal Register on page 60618, middle column, second paragraph: “The regulations finalized today therefore provide that where an emissions trading program has been designed

### 38 Commenter Comment # Section Comment DEQ Response to meet a requirement other th an BART, including the reasonable progress requirement, the State may establish a BART benchmark based on an analysis that includes simplifying assumptions about BART control levels for sources within a source category.”

US Forest

Service D98 BART: Jim Bridger and Naughton The FS notes that the 309 program sunsets in 2018, and that additional SO 2 controls may be appropriate for reasonable progress at that time. The Division is aware that the 309 program only establishes milestones through 2018, and that following 2018 another strategy may be necessary to reduce visibility

- impairing pollutants. Additional strategies will be addressed in future SIP revisions

.

US Forest

Service D99 BART: Jim Bridger and Naughton US EPA BART guidelines state that 0.5 dv “contributes” to impairment, and 1.0 dv “causes” impairment. The discussion from Ronald Henry is irreverent and used in an improper

context. The Division did not attempt to endorse a particular threshold for human eye “perceptibility” since the level of p erceptibility has long been disputed. Instead, the Division has relied on EPA’s Appendix Y BART guidance, which suggests a value of 0.5 dv as the level that a source “contributes” to visibility impairment. One of the metrics used by the Division to evalu ate the relative benefit of a given BART control option was the number of days yielding a modeled impact of 0.5 dv or more

.



## E. **Analysis of 309 (g)**  **Comments Received in Response to the December 8, 2010 Public Hearing**

Commenter Comment # Section Comment DEQ Response

Powder River
Basin
Resource Council E1 Better than BART Demonstration DEQ continues to fail to adequately demonstrate that the backstop trading program is “better than BART”. DEQ cannot rely upon the high level WRAP analysis in place of a unit

- by

- unit specific BART analysis. DEQ’s reliance on the WRAP “Better than BART” determination is undercut by actions in states across the region that are implementing BART limits that are stronger than the SO 2 limits at power plants in Wyoming. While BACT may not necessarily equate to BART, the limits imposed at these new plants demonstrate that a thorough BART analysis is needed in light of improved technology efficiencies and costs. The Regional Haze rule do es not require that the State perform a unit

- by

- unit specific BART analysis to demonstrate t hat the Backstop Trading P rogram is “Better than BART”. EPA clearly explains the intent for the Rule in the Federal Register, Volume 71, No. 198, Dated October 13, 2006 / Rules and Regulations, in the second paragraph on page 60615: “ As discussed in more detail below, today’s rule also makes clear that where a trading program or other similar alternative program has been designed primarily to meet a Federal or State requirement other than BART, the State can use a more simplified approach to demonstrating that the alternative program will make greater reasonable progress than BART.” The following statement is also made in the same Federal Register on page 60618, mid dle column, second paragraph: “The regulations finalized today therefore provide that where an emissions trading program has been designed to meet a requirement other than BART, including the reasonable progress

### 39 Commenter Comment # Section Comment DEQ Response requirement, the State may establish a BART benchmark based on an analysis that includes simplifying assumptions about BART control levels for sources within a source category.”

Therefore, DEQ believes that the State ’ s “Better than BART” determination is adequate. As demonstrated, EPA does not requ ire the analysis to be performed on a unit

- by

- unit basis. Since the procedure for making the “Better than BART” determination meets EPA ’ s requirements, DEQ does not believe that a thorough BART analysis needs to be performed in light of improved technolog y efficiencies and costs.

Powder River Basin Resource Council E2 General All of Wyoming’s Class I areas (and Class I areas in South Dakota that are impacted by Wyoming sources) are off of the Colorado Plateau. Therefore, these are additional Class I areas that must be addressed through the 309(g) plan. DEQ must fully discuss these Class I areas and establish enforceable goals. The D ivision believes that the additional Class I areas that are located outside the Colorado Plateau are appropriately addressed in the 309 SIP. The State has modeled visibility in the additional non

- plateau Class I area monitor locations. Table 6.2

- 2, demonstrates visibility in Wyoming and surrounding states broken down by sulfate extinction only. It can be seen in this table th at all Class I areas show visibility improvement for the worst days, and no degradation in visibility for the best days, thereby meeting the requirements outlined in the Regional Haze Rule. In addi tion, Table 6.2

- 1 outlines the R egional SO 2 Emissions and Milestone R eport summary. This table demonstrates that the 309 states have had significant SO 2 reduction and have more than exceeded the goals set by the program

.
The Regional Haze R ule requires that the above demonstration is necessary, as well as a demonstration that the milestone s provide greater reasonable progress than BART. This demonstration can be found i n Appendix E, Demonstration that the SO 2 Milestones Provide Greater Reasonable Progress than BART. As long as this demonstration is performe d, u nder
t he Regional Haze Rule, EPA allows the S tate to take credit for any SO 2 reduction achieved in S ection 309, as stated in 51.309(g)(i): “ In developing long term strategies pursuant to 51.308(d)(3), the state may build upon the strategies implemented under paragraph 9 ( d) of this section, and take full credit for the visibility improvement achieved through these s trategies. ” However, if the URP goal is not met, the Rule does not require SO 2 sources to undergo further reduction in order to meet this g oal. If the URP goal cannot be met for a given planning period, it is the requirement that the State demonstrate why this goal cannot be met, which the State believes it has done throughout the SIP.

Therefore, the State believes that the additional Class I areas are appropriately addressed in the 309 SIP, and it is not necessary to further discuss SO 2 enforceable goals in the 309(g) SIP.

### 40 Commenter Comment # Section Comment DEQ Response

Powder River Basin Resource Council E3 Modeling, Monitoring and Emission

Inventories DEQ must fully document the technical basis for the SIP, including monitoring data, modeling, and emission information, including the baseline inventory upon which its strategies are based. Additionally, the SIP should consider “major and minor
stationar y sources, mobile sources and area sources”. Wyoming’s SIP is deficient because it does not properly account for all relevant emission sources or use available monitoring and modeling information. The regional haze emissions inventory for all Western stat es was compiled by WRAP. The inventory data used for this SIP was pulled from WRAP ’ s Emissions Data Management System (EDMS) warehouse. This warehouse facilitates regional emission data collection using a consistent and comparable approach between states . The emissions source categories contained in this warehouse are point/stationary, area non

- point, on road mobile, off road mobile, fires, windblown dust, and biogenic. The following website contains a description of EDMS, as well as an inventory descr iption, including the inventory compiled for this SIP: http://www.wrapedms.org/ . Emission inventory summaries can be found in Tables 4.2

- 1 through 4.9

- 1.

The modeling that was used for Wyoming’s SIP as well as a ll other Western states, was performed by WRAP . This is a complete model that allows W estern states to compare results that were obtained using identical methodologies. The Division believes that it is appropriate to use only these modeling results.

Moni toring results were obtained from the IMPROVE sites identified in Chapter 2. These are
EPA

- approved monitors that are recognized by all state and federal authorities.

The compiled emissions inventories, as well as modeling and monit oring data can be found in the Technical Support D ocument, as well as on the following website (which is referenced heavily in the Technical Support Document) : http://vista.cira.colostate.edu/tss/Resu lts/HazePlanning.aspx

.

Powder River Basin Resource Council E4 Oil and Gas Emissions The draft SIP explains that DEQ cannot include a full inventory of oil and gas related emissions because the modeling and monitoring has not been completed. DEQ ignores a wealth of information about oil and gas related emissions that can easily be integrated into the regional haze plan. DEQ has obtained substantial funding through Abandoned Mine Lands funding o undertake modeling and monitoring efforts of air quality in

en ergy impacted areas. There is also significant information available from the BLM Environmental Impact Statements for oil and gas development. Finally, DEQ should have a wealth of information on facilities that are operated under Title V permits. DEQ is aware that there is an abundance of oil and gas related information. However, there is not a clean inventory available that contains information compiled using a systematic method. WRAP is working on such an inventory right now in Phase III of its projec t. DEQ is awaiting this inventory, not modeling and monitoring results.

Oil and gas inventories are complicated to quantify. It is true that the DEQ has access to Title V emissions data, but this is a very small fraction of the total emissions. To compi le a complete inventory, every source must be looked at right down to the wellhead level. This includes the emissions associated with drilling and completing each well, which in itself is very complex. To name a few, the drilling and completion process a lone has emissions associated with trucking

### 41 Commenter Comment # Section Comment DEQ Response trips for various fluids and pieces of equipment, drill rigs, completion rigs, wirelines, and fraccing equipment. Each well has different emissions associated with each activity. After the well is drilled and c ompleted, the production process begins and there will be emissions associated with various pieces of production equipment such as tanks, flares, dehy units, compressor stations, fluid trucking, and pipeline losses. To account for all of these emissions, some of the things that must be known are how many pieces of production equipment are in the state, what types of controls each unit has, and how much oil and gas is being produced from each facility. These are only some examples of the complexity of an i nventory development for oil and gas sources. A complete inventory will have t o look at many more aspects than what was just outlined.

The BLM Environmental Impact Statements are to be used by the BLM as a decision making tool, not an implementation plann ing and regulation development tool. In addition, all information is pre

- decisional until a draft document has been released to the public and is not approved until a Record of Decision is released.

The State of Wyoming is making great strides for identif ying and quantifying sources and emissions from new fields. However, it is much more difficult to quantify emissions associated with older fields in the state. The Division has started collecting inventories for oil and gas sources. The WRAP study will assist the State in understanding all of the sources that need to be evaluated.

Powder River
Basin
Resource Council E5 Coal Mines Coal Mines in Wyoming, particularly large surface mines in the Powder River Basin, are significant area sources of haze

- causing pollution including NO x and p articulate matter. Coal mine related emissions data is easily available to DEQ through BLM Environmental Impact Statements, to which DEQ is a cooperating agency. DEQ should prioritize coal mine emissions as part of its regional haze plan. NO x and PM emissions from coal mines were taken into account in the development of the emissions inventory. The Dust Emissions document (under the following link: http://vista.cira.colostate.edu/TSS/Results/Emissions.aspx ) summarizes all sources used to develop the PM portion of the inventory. Mining operations are included in this list. It is difficult for DEQ to prioritize the coal mine emissions since most of the NO x is generated by trucks and railroads, which is regulated by EPA. The State does not have the authority to regulate mobile sources. However, there are some area source NO x emissions included in the inventory. WRAP

- developed pivot ta bles summarize the PM and NO x emissions that result from mining operations: http://www.wrapair.org/forums/ssjf/pivot.html . As explained in the above comment response, Environmental Impact Stat ements are to be used by the BLM as a

### 42 Commenter Comment # Section Comment DEQ Response decision making tool, not an implementation planning and regulation development tool. In addition, all information is pre

- decisional until a draft document has been released to the public and is not approved until a R ecord of Decision is released.

Powder River Basin Resource Council E6 Visibility DEQ should explain visibility conditions and progress goals for all Class I areas within 300 km. This includes not just Class I areas in Wyoming, but all Class I areas that are impacted by Wyoming pollution. We especially encourage DEQ to explain conditions and progress goals for Badlands and Wind Cave National Parks, which are impacted by current sources of pollution and are greatly threatened by future sources and increasi ng industrial development in the Powder River Basin. DEQ cannot set progress goals for Class I areas outside of Wyoming. The Division only has the ability to set goals within the State ’ s jurisdiction. However, DEQ has not ignored Wyoming’s contribution to visibility impairment in the surrounding states. Tables 8.1.2.1

- 1 and 8.1.2.1

- 2 summarize Wyoming’s sulfate and nitrate contribution to regional haze in the closest Class I areas for all surrounding states. Badlands and Wind Cave National Parks are in cluded in these tables. There is no requirement in the rule that the State look at all Class I areas within 300 km
, and instead chose the approach of analyzing the Cla ss I areas closest to the state and fanning out further if any significant contributions were observed.

Powder River
Basin
Resource Council E7 Visibility on Reservation There is a need to refer briefly to the Class I area of the Northern Cheyenne Indian Reservation (NCIR). While the NCIR Class I area in not a “mandatory” Class I area under th e Regional Haze Rule, it is a significant Class I area with ecological and cultural importance that is impacted by industrial pollution from Wyoming. The DEQ recognizes that the Northern Cheyenne Indian Reservation is an area with ecological and cultural importance. Since this Class I area is not a mandatory area under the Regional Haze Rule, it is not necessary to include a projection of the improvement in visibility. However, the State has worked closely with the Tribe. Tribal consultation description s can be found in Section 11.3 of the SIP and Chapter 11 of the TSD.

Powder River Basin Resource Council E8 Reasonable Progress

Goals DEQ’s new plan does not include enforceable emissions limitations, especially for minor and area sources. DEQ assumes that emissions will be greatly reduced from area and minor sources without explaining how and when these reductions will take place. Industrial development in Wyoming is increasing

– not decreasing

– and therefore emissions will only increase in the years to come. Wyoming’s SIP includes a number of enforceable emission reduction actions, with compliance schedules to ensure the reasonable progress goals are achieved. There are three categories of steps being taken to achieve the reasonable progress goal. This first includes a variety of emission reductions due to p rograms already in place. The S tate has implemented a number of enforceable permit programs with the goal of reducing emissions. These programs include New Source Review (NSR), Prevention of Signif icant Deterioration (PSD), Minor Source Best Available Control Technology (BACT), and Title V permitting. The State has also adopted New Source Performance Standards (NSPS), the Phase I Visibility Rule, and National Emission Standards for Hazardous Air Po llutants (NESHAPs) from EPA into Wyoming’s Air Quality Standards and Regulations (WAQSR). Additional ongoing programs include implementation of federal mobile source regulations, implementation of programs to meet PM 10 National Ambient Air Quality Standar ds (NAAQS), development of a Nonattainment SIP for PM 10 for the

### 43 Commenter Comment # Section Comment DEQ Response City of Sheridan, preparation of a natural events action plan, establishment of Chapter 3 in WAQSR to mitigate impacts of construction activities, source retirement and replacement schedules, and agricultural and forestry smoke management techniques. All programs listed are enforceable at the S tate level through the WAQSR or permits. Each program is described in more detail in Section 8.2 of the SIP.

The second category of emission reduction techniques is BART determination and installment. Table 6.4

- 1 summarizes all of the BART determination s made for Wyoming sources. All BART sources are enforceable through BART permits and contain compliance schedules.

The last category of emission reduction techniques are the additional requirements that the State is placing on Laramie River Station and Jim Bridger Power Plant. A description of these strategies can be found in Section 8.3.3. The requirements are enforceable through permits and con tain compliance schedules.

DEQ does not assume that area source emissions will decrease in the future. The State takes into account growth factors for industrial development. Tables 4.2

- 1 and 4.3

- 1 demonstrate
an increase in NO x area sources due to indus trial growth.

Powder River Basin Resource Council E9 Oil and Gas The draft SIP explains that new regulations would be needed in order to reduce oil and gas emissions. DEQ does not address any efforts to undertake the needed regulations. DEQ does not

even fully explain what emissions reductions would be possible under new regulations. DEQ cannot complete the evaluation of oil and gas impacts on visibility until Phase III of the WRAP study has been complete d

. Until the evaluation has been finalized and emis sions from oil and gas sources are better understood, it is difficult to determine what new regulations will be necessary or what reductions can be achieved by the regulations. The development of new rules and regulations will also occur in parallel as th e State addresses ozone.

Powder River
Basin
Resource Council E10 Coal Mines There is no discussion in the SIP about enforceable reasonable progress goals for coal mines. Reasonable Progress G oals are not set for individual source categories. The goals are set for each Class I area and incorporate all sources in that area, including coal mines.

### 44 Commenter Comment # Section Comment DEQ Response

Powder River Basin Resource Council E11 Plan Evaluation DEQ fails to discuss evaluation of the plan and what additional actions will be taken if visibility improvement goals are not being
met. Under the Regional Haze Rule, the State is required to submit an evaluation of the plan every 5 years following the init ial submittal of the SIP. The S tate has committed to submitting a report on reasonable progress every 5 years. The requirement of the evaluation report can be found in Chapter 10 of the SIP.

Powder River
Basin
Resource Council E12 BART The SIP must include updated information regarding the BART process. The settlement agreements for coal fired power plants

are available on the EQC website, but not on DEQ’s. Thus, any interested parties would essentially be unaware of these settlement agreements and could not comment on them as part of the draft SIP. As the BART process is perhaps the most important component o f the regional haze SIP, it is important that this portion of the plan be finalized prior to public notice and comment. Since the portion of the plan related to BART is not finalized in this draft, DEQ should re

- release the plan for public comment. The public comment process on the draft RH SIP provided adequate notice and an opportunity for meaningful participation. Section 6.5.8 of the draft RH SIP for 309(g) stated that "BART permit for Basin Electric Power Cooperative

- Laramie River Station is under appeal before the Wyoming Environmental Quality Council, docketed as Case No 10

- 2802, and is subject to change ” . Section 8.3.3 included similar language and also stated that " BART permit for PacifiCorp

- Jim Bridger Power Plant is under appeal before the Wyoming Environmental Quality Council, docketed as Case No. 10

- 2801, and is subject to change. " These statements appear to have adequately informed commenter’s that they should file comments on these subjects during the public comment period because c hanges to these sections were possible.

Powder River Basin Resource Council E13 BART DEQ must fully demonstrate th r ough a plant by plant analysis that the SO 2 backstop trading program is better than BART. Additionally, the Section 309 backstop trading program may only excuse the DEQ from establishing SO 2 BART emission limits if that program has been approved by the EPA. DEQ ’ s 309 program has not been approved by EPA, as evidenced by it being out currently for public comment. Without an approved Section 309 SIP, DEQ must establish BART for SO 2 emissions

. The State believes that the Better than BART determination was done app ropriately. The Regional Haze R ule does not require that the State perform a unit

- by

- unit specific BART

an alysis to demonstrate that the Backstop Trading P rogram is “Better than BART”. EPA clearly explains the intent for the Rule in the Federal Register, Volume 71, No. 198, Dated October 1 3, 2006 / Rules and Regulations, in the second paragraph on page 60615: “ As discussed in more detail below, today’s rule also makes clear that where a trading program or other similar alternative program has been designed primarily to meet a Federal or Sta te requirement other than BART, the State can use a more simplified approach to demonstrating that the alternative program will make greater reasonable progress than BART.” The following statement is also made in the same Federal Register on page 60618, m iddle column, second paragraph: “The regulations finalized today therefore provide that where an emissions trading program has been designed to meet a requirement other than BART, including the reasonable progress requirement, the State may establish a BAR T benchmark based on an analysis that includes simplifying assumptions about BART control levels for sources within a source category.”

The original vision of the EPA Regional Haze Rule developed in 1999 was to complete Section

### 45 Commenter Comment # Section Comment DEQ Response 309 before 309(g), which ena bled Section 309(g) to take credit for the SO 2 reductions. The original deadline for the 309 submittal was 2003, while 309(g) wasn’t due until 2008. Since this time, the State has submitted two SIPs to EPA and will submit its third revision in early
2011 . EPA has also changed the Rule several times, and pushed back the 309 submittal until 2007. Due to delays, the process has been taking longer than expected and the 309 and 309(g) processes are now overlapping, and SIP submittal for both programs are occ urring in parallel.

Powder River Basin Resource Council E14 BART PacifiC orp proposed to meet a BART limit of 0.015 lb/ MM Btu for its Wyoming power plants. It remains unclear why DEQ rejected this analysis and instead proposed higher limits at some of the plants. Recent Prevention of Significant Deterioration (PSD) permits issued by the Division did include PM/PM 10 l imit s of 0.012 lb/MMBtu for fabric filter controls, but those limits (and PM/PM 10 l imit s established for the Desert Rock Project in New Mexico) were determined through Best Available Control Technology (BACT) analyses for new sources. The BART process deals with retrofit controls on existing units , and therefore is not directly comparable to BACT determinations. Additionally, visibility modelin g described in the Division’s BART analysis for the Jim Bridger plant showed that the addition of a fabric filter to replace an Electrostatic Precipitator (ESP) provided very little in the way of visibility improvement, with predicted cumulative improvemen ts across three Class I areas of only 0.03 to 0.1 Δdv for Units 1

- 4. These results indicate that requiring more stringent control levels for a fabric filter would not provide significant visibility improvement.

Powder River Basin Resource Council E15 BART It was stated that the DEQ should fully consider the comments of the federal land management agenc ies and other information that is widely available for demonstrating the cost

- effectiveness of achieving lower BART limits. The DEQ fully considers the comments received from the Federal Land M anagers and all other interested parties. Each BART per mit went out for public comment , and were responded to by DEQ. BART comment response s can be fo und in the TSD under Chapter 11, Summary of FLM (and Other) Com ments on BART and State Responses on BART . Permi t applications and State analyse s can be found in Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp

.

Powder River Basin Res ource Council E16 BART The PRBRC commented that the DEQ’s preliminary BART determination for the Laramie River Station (LRS) was SCR on all three units, but due to Basin Electric’s claims that funding would be difficult to obtain to allow installation of SCR within the BART
time frame, the DEQ did not require SCR as BART. The PRBRC believes that SCR should be required for all three LRS units as BART, should be installed within the 5

- year BART timeframe, and that these requirements should be implemented as part of the Regional Haz e SIP. At the very least, the PRBRC believes that In determining BART for the three units at LRS , DEQ

- AQD considered all fiv e BART statutory factors. During the cost of compliance evaluation, the AQD recognized that a time limitation to install BART

- determined controls was imposed by the Regional Haze Rule, but timing of control installation was not explicitly considered in th e BART statutory factors. Based on the control costs and visibility modeling presented by Basin Electric in the BART applications for the LRS, and taking into consideration the logistical challenge of managing multiple pollution control installations with in the 5

- year regulatory timeframe allotted for BART, the AQD required installation of SCR (or equivalent) on two LRS units under the Long

- Term Strategy of the Wyoming Regional Haze State Implementation Plan (SIP). A legal appeal of that Long

- Term Strateg y requirement by Basin Electric and subsequent negotiations between Basin Electric and the AQD led to a settlement agreement that will require the LRS to install NO x controls that

### 46 Commenter Comment # Section Comment DEQ Response presumptive BART limits should be considered. DEQ should also consider the current NSPS limits for NO x for new coal

- fired plants

. will achieve emissions that are lower than the EPA’s presumptive BART levels on all three LRS units. These controls must be installed within the BART timeframe. Further reductions will be required by the end of 2017 that are the equivalent of the addition of SCR control on one of the LRS units.

Consideration of NSPS limits that are intended for new coal

- fired plants is not relevant for the determination of BART, because BART pertains to existing sources that may not be configured to accommodate the emissions limits that can be achieved by newly c onstructed sources.

Powder River Basin Resource Council E17 Long

- Term Strategy DEQ ’ s long

- term strategy proposal regarding NO x emissions (i.e., settlement agreement) at the LRS is problematic because required levels are based on the total emissions for all three units combined. The PRBRC believes that the DEQ should analyze unit by unit limits. The AQD established a plant

- wide NO x limit for the LRS under Condition 7d of the settlement agreement to allow Basin Electric the flexibility to achieve the emissio ns reductions by applying additional controls on any or all of the LRS units. The plant

- wide emission limit will be the equivalent of the EPA’s presumptive BART level on two of the LRS units and SCR control on one of the LRS units.

Powder River Basin Res ource Council E18 Long

- Term Strategy The SIP must provide a long

- term strategy for achieving reasonable progress towards meeting natural visibility conditions by 2064. DEQ is implementing modest goals with minor improvements in visibility when significant reduction are possible to greatly improve visibility in Class I areas sooner than later. DEQ believes that the State is achieving reasonable progress for this planning period. Section 51.308(d) of t he Regional Haze Rule states that “ The reasonable progres s goals must provide for an improvement in visibility for the most impaired days over the period of the implementation plan and ensure no degradation in visibility for the least impaired days over the same period ”. Even though the Uniform Rate of Progress (URP) was not achieved in this planning period, the requirements for the reasonable progress goals set under the Regional Haze Rule have been achieved. According to 51.308 (d)(1)(i)(B ) “For the period of the implementation plan, if the State establishes a reasonable progress goal that provides for slower rate of improvement in the visibility than the rate that would be needed to attain natural conditions by 2064, the State must demonstrate, based on the factors in paragraph(d)(1)(i)(A) of this section, th at the rate of progress for the implementation plan to attain natural conditions by 2064 is not reasonable; and that the progress goal adopted by the State is reasonable.” DEQ believes that an adequate demonstration has been made as to why the goals set b y the State are reasonable. This can be found in Section 7.6. Overall, a combination of natural and international emissions which the DEQ has no control over is the primary cause of the Division ’ s inability to achieve the URP.

Powder River
Basin
Resour ce Council E19 Long

- Term Strategy SCR should not be part of the long term strategy and instead should be required as BART. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulations (WAQSR), as well as EPA’s Subpart Y Guidance. All BART sources underwent DEQ ’ s permitting process, an d went out for public comment . DEQ responded to each comment. All comments and respons es can be found in the TSD , under Chapter 11, Summary of FLM (and Other) Comments on BART and State Responses on BART

. Refer to A ttachme nt A of the SIP for BART analyse s, applications,

### 47 Commenter Comment # Section Comment DEQ Response and additional information for the applicable sources at: http://deq.state.wy.us/aqd/regionalhaze.asp

. Powder River Basin Resource Council E20 Long

- Term Strategy DEQ should consider closure of coal

- fired plant units as a long term strategy option. DEQ cannot consider the closing of coal

- fired power plants unless it is proposed by the companies that own them. The Division has had discussions with t he unit operators, and all operators are looking at reducing emissions rather than shutting down the facilities. If a

com pany were to propose the shut

- down of a facility in the future, it would be evaluated in future SIPs.

Peabody

Energy E21 Reasonable Progress

Goals Peabody fully supports the Air Quality Division’s RPG analysis and believes that the RPGs proposed represent an attainable standard. The Regional Haze Rule sets no presumptive target for making determinations of RPGs, and does not mandate specific rates of progress. Although the 2018 RPGs are less than the 2018 URP, they nevertheless represent a realistic and att ainable improvement over baseline conditions. DEQ agrees that the Division ha s properly justified why the URP s could n ot be attained. DEQ appreciates Peabody’s recognition of the State ’ s RPGs.

Peabody

Energy E22 Long

- Term Strategy Peabody commends the Air Quality Division’s plan, outlined in the Long

- Term Strategy section of its SIP, to apply the terms of its Natural Events Action Plan to moderate the impact of uncontrollable natural events on visibility in the state. DEQ appreciates Pe abody’s recognition o f the Long

- Term Strategy to moderate uncontrollable

na tural events visibility in the s tate.

Peabody

Energy E23 General Peabody notes that Wyoming has taken steps to ensure meaningful visibility improvements through the requirement of significant reductions in controllable, anthropogenic emissions of sulfur dioxides (SO 2 ) and nitrogen oxides (No x ) emissions via the implementation of BART requirements and other control measures. While the reduction falls short of the URP goal, Peabody believes that the Air Qu ality Division has presented ample evidence that natural and international emissions are the cause of this shortfall, and that it has required all emission reductions from in

- state sources that it reasonably can. DEQ appreciates Peabody’s recognition of the reasonable steps that the Division has taken to reduce emissions.

Peabody

Energy E24 BART In general, Peabody supports the Air Quality Division’s BART analysis

– using a “top

- down” framework is consistent with EPA DEQ appreciates Peabody’s support for the Division’s BART analysis approach.

### 48 Commenter Comment # Section Comment DEQ Response guidance and provides a rational and del iberate means for analyzing potential control alternatives.

Peabody

Energy E25 BART Peabody Energy commented that some of the AQD BART determinations appear to be driven by the fact that the facility was already planning to install certain control equipment, and the SIP should explain if controls are required under other authority or a negotiated settlement. Peabody notes that costs cited for SCR and fabric filters appear low. Peab ody also noted that the AQD deemed the costs of fabric filters to be unreasonable, but accepted fabric filters as BART. Other BART determinations developed under similar circumstances should be fully explained in the SIP. Peabody suggests alternatives fo r the AQD in order to avoid setting an inappropriate precedent for BART determinations. Peabody suggested that the SIP could consider controls that facilities already plan to install to be the baseline condition for evaluating other control options, or th at the cost

- effectiveness calculation could be eliminated if the source does not seek to rule out the most effective control on the basis of cost

- effectiveness. Several of the facilities that were subject to BART committed to pollution control projects prior to submittal of BART applications to the AQD. The Division thoroughly evaluated all control alternatives, including those already installed or proposed to be installed, and determined
BART b ased on consideration of all five statutory BART factors as required by EPA’s Appendix Y BART guidance. Fabric filters were selected as BART for PM control for several sources that intended to install the fabric filters as part of pollution control projects. Estimated costs for the fabric filters are deemed by the AQD to be reasonable when considering all factors relating
to t he existing PM controls in addition to those considered for the BART analysis (AQD and PacifiCorp BART Appeal Settlement Agreement , Wyoming Environmental Quality Council, November 9, 2010).

Costs presented by BART applicants were developed using source s such as the EPA OAQPS Control Cost Manual, vendor

- obtained price quotes, and engineering database s. All costs were scrutinized by AQD permit engineers as part of the permit application review process. The commenter did not provide specific examples of c ontrol equipment costs that they believed to be underestimated, and therefore the AQD cannot provide specific responses.

The alternative proposed by the commenter that would include consideration of controls already to be installed as baseline would not be acceptable to the AQD. 40 CFR 51.309(b)(7) provides guidance for the selection of the baseline year for BART, and the baseline year chosen using this guidance was 2003. All control alternatives that represented additional control beyond the baseline con dition were individually evaluated by the AQD as possible BART alternatives without regard to the source’s intention to install particular sets of controls. The suggestion that the AQD eliminate the cost

- effectiveness evaluation altogether in cases where a source intends to install controls regardless of costs is not acceptable to the AQD. The Division determined BART based on consideration of all five statutory BART factors, including the costs of compliance, and would continue to present complete inform ation for each evaluation factor.

### 49 Commenter Comment # Section Comment DEQ Response

Peabody

E nergy E26 BART As an alternative to the EPA guidance recommended “dollar

- per

ton” cost

- effectiveness calculation, Peabody submits that a “dollar

- per

- deciview” approach may represent a more appropriate means. EPA’s Appendix Y BART guidance does mention that “dollars per deciview” ($/dv) is a metric that could be used to evaluate the cost of BART compliance, but by no means identifies $/dv as an essential or required metric. The Division considered capital cost , annual cost, cost effectiveness, and incremental cost effectiveness in the cost evaluation of each proposed BART control option

. The Division chose not to use a hybrid metric such as $/dv primarily because of the lack of historical precedent regarding r easonable/acceptable levels for such a metric. Additionally, the use of a hybrid cost metric such as $/deciview can introduce uncertainty as to how the value was calculated. The value of “/deciview” could be based on the highest modeled value in a given area or the 98 th percentile modeled value. It could be based on the
98 th percentile value for any one modeled year or it could be an average for multiple years. It could even be based on an average modeled value across an entire Class I area or the sum o f deciview changes across multiple areas. The Division has found that $/dv values are often presented without explanation of the basis for the calculation. To avoid these confounding factors, the Division chose to evaluate and present the cost analyses a nd visibility analyses separately.

Peabody

Energy E27 BART Peabody Energy commented that it is meaningless to rely upon cumulative visibility modeling results because of the manner in which visibility impacts are modeled. Peabody recommends that the AQD revise the Regional Haze SIP to remove all references to cumulative visibility improvements. The AQD agrees that reporting cumulative visibility modeling (CALPUFF) results can at times lack clear meaning. For determining the visibility impacts for units t hat were subject to BART, the AQD modeled each unit separately as recommended in EPA’s Appendix Y guidance. Results of the modeling were reported for individual units in terms of the 98 th percentile delta

deciview (dv) impact at particular Class I areas o r in terms of the number of days with greater than a 0.5 dv impact at a particular Class I area. Any mention in the SIP of “cumulative” results for BART determinations pertains to the sum of the 98 th percentile results for a particular unit for the (two o r three) closest Class I areas. The AQD believes that the consideration of the summed results, along with a strong consideration of the results at individual Class I areas, was an appropriate approach for the BART determinations.

Peabody

Energy E28 BART Peabody Energy disagrees with the AQD’s consideration of other environmental factors in making BART determinations. For example, a statement on page 109 of the SIP describes that “enhanced mercury removal co

- benefits” were part of the justification for a fabric filter on Naughton Unit 3 as BART. As described in Section 6.5.6 of the SIP, the AQD concluded that the costs for a fabric filter for Naught on Unit 3 are reasonable, based on consideration of all the factors above and beyond the benefits associated with regional haze. This approach to assessing the costs associated with the fabric filter was prompted by a settlement agreement between the AQD and PacifiCorp. (AQD and PacifiCorp BART Appeal Settlement Agreement, Wyoming Environmental Quality Council, November 9, 2010 ).

### 50 Commenter Comment # Section Comment DEQ Response Peabody contends that such additional considerations are beyond the scope of the EPA’s BART regulations.

Peabody

Energy E29 Long

- Term Strategy Peabody supports the Air Quality Division’s proposed Long Term Strategy in that it takes steps towards collecting and analyzing additional information that will help the state determine whether additional controls may be imposed on non

- BART eligible sources. DEQ appreciates Peabody’s recognition of the efforts the State is making to determine additiona l controls that can be imposed o n non

- BART sources.

Basin Electric
Power Cooperative E30 General Basin Electric summarized the BART settlement, and the

co mpany’s opinions on the settlement

. DEQ has received Basin Electric’s summary of the BART settlement. There were no specific requests made that the Division needs to address. The DEQ will adhere to its portion of the settlement agreement.

Forest Service E31 Oil and Gas In Section 8.3.5, Wyoming indicates that the DEQ can’t complete evaluation of oil and gas contributions without the WRAP Phase III report. The FS understands that the Phase III work is in progress for the Wind River, Upper Green River, and Powder River Basins. We look forward to Wyoming addressing this important emission catego ry when the Phase III report is completed; however these reports apparently will not address oil and gas development in the entire state. The WRAP Phase III report contains the basins identified by the Forest Service, as well as Big Horn and Denver Basin. It also includes the entire Green River Basin, not just the Upper Green River. The project scope includes “all Rocky Mountain states’ basins with significant oil and gas development activity”. The Project Scope document identifies the boundaries for Wy oming basins: http://www.wrapair.org/forums/ogwg/documents/Phase_III_Oil&Gas_EI_project_Scope_of_ Work_Final_110507.pdf

The map on page 4 of this document prepared by ENVIRON illustrates that all areas in Wyoming that have significant oil and gas development are covered in the WRAP Phase III Report.

Forest Service E32 BART Figure 8.3.6

- 7 does not appear to reflect the changes in BART compliance dates. This figure has been changed in the SIP.

Earthjustice E33 General AQD inexplicably relies on Wyoming ’s relative clean air as a justification for failing to meet more stringent visibility milestones. It is not DEQ ’ s intention to rely on its “relative clean air” as a justification for not meeting more stringent visibility milestones. The Division wanted to outline the difficulty of the task expected, but in no way is the DEQ using the “relative clean air” as an excuse for not achieving the U RP goal. DEQ is trying to demonstrate that it is not as easy to show progress when there are fewer initial visibility impacts. DEQ explains in the SIP that the URP goal is diff icult to achieve due to forest fire impacts in the state. Therefore , the lack of URP goal achievement is

### 51 Commenter Comment # Section Comment DEQ Response not an issue of motivation by the State, but rather an issue of environmental impacts beyond the Division ’ s control.

Earthjustice E34 Greater Reasonable Progress than BART The alternative 309 program does not appear to be an improvement over BART for Colorado Plateau Class I area s . AQD must either demonstrate the superiority of the alternative program based on complete and accurate information, or require installation and operation of BART for SO 2 emissions at Wyoming sources subject to BART. The Division has demonstrated the superiority of the 309 program in the Demonstration that the SO 2 Milestones Provide Greater Reasonable Progress than BART document in Appendix E

. In this demonstration, the S tate not only verifies that t he program meets or exceeds presumptive SO 2 BAR T levels, but also provides other benefits of implementing the milestone program. One of these benefits includes limiting new source growth for SO 2 emissions in the participating states. In addition, the pro gram includes every source that emits 100 tons per year or greater of SO 2 , and therefore targets a greater number of sources than what would be identified in the BART program. DEQ believes that this conclusion is based on complete and accurate information

.

Earthjustice E35 Greater Reasonable Progress than BART In most cases this “Better

- than

- BART” determination must be based on an analysis of BART technology and corresponding emission reductions achievable for each source that is subject to BART within the state. By relying on an inflated presumptive SO 2 emission rate for power plants, rather than a lower emission rate achievable through BART, WRAP has improperly discounted the visibility improvement that may be achieved through implementation of BART on el igible sources. It is not required by the Regional Haze Rul e that the State perform source

- specific BART analyses to determine that the 309 program has achieved better than BART reductions. EPA clearly explains the intent for the Rule in the Federal Register, Volume 71, No. 198, Dated October 13, 2006 / Rules and Regulations, in the second paragraph on page 60615: “ As discussed in more detail below, today’s rule also makes clear that where a trading program or other similar alternative program has bee n designed primarily to meet a Federal or State requirement other than BART, the State can use a more simplified approach to demonstrating that the alternative program will make greater reasonable progress than BART.” The following statement is also made in the same Federal Register on page 60618, middle column, second paragraph: “The regulations finalized today therefore provide that where an emissions trading program has been designed to meet a requirement other than BART, including the reasonable
progre ss requirement, the State may establish a BART benchmark based on an analysis that includes simplifying assumptions about BART control levels for sources within a source category.”

Since EPA allows the State to use a simp lified approach to analyze BART

- eligible sources, i t is appropriate to use 40 CFR p art 51 Appendix Y to determine presumptive levels, rather than look at each source separately.

Therefore, the State believes that the “Better than BART” determination has been conducted appropriately, and no further analysis is required.

### 52 Commenter Comment # Section Comment DEQ Response

Earthjustice E36 Greater Reasonable Progress than BART AQD apparently intends to rely o n WRAP’s “better

- than

- BART” determination. However, WRAP’s analysis does not support its “better

- than

- BART” finding. Even if WRAP’s reliance on EPA’s presumptive SO 2 emissions limit for power plants was appropriate, it has failed to establish that the 309 alternative program achieves “greater reasonable progress” than BART. WRAP concedes that the alternative program will, at best, res ult in the same SO 2 reductions achievable through the application of BART. WRAP justified the determination in part through its claim that emission reduction s will happen sooner under the alternative program than under BART. WRAP’s Demonstration that the SO 2 Milestones Provide Greater Reasonable Progress than BART report (provided in Appendix E ) does support the State’s better than BART finding. On Page 12 of the report it states
, “ The Regional SO 2 milestone of 141,849 equals the BART benchmark, but provides greater reasonable progress than BART for the reasons outlined below..... ” The report continues to explain the additional advantages of the 309 program such as early reductions, the addition of s ources that would not be included in BART, a cap in new source growth, the inclusion of strategies to address mobile sources, prescribed fire, pollution prevention and clean air corridors, tribal set asides, and an improvement in Class I areas off of the C olorado Plateau. The report does not state that “emission reductions will happen sooner under the alternative program than they would under BART”, but rather that the program will

“ contain specific provisions to encourage and reward early emissions reduct ion... ”

. This program has achieved a 60% SO 2 reduction from 1990 to 2008, verifying that this program has been successful in achieving early reduction. DEQ believes that WRAP has adequately demonstrated that the 309 program has achieved better than BART p rogress.

Earthjustice E37 General The draft 309(g) SIP fails to justify Wyoming’s adoption of an
emissions

- reduction strategy that would not achieve the “uniform rate of progress” necessary to restore natural visibility conditions by 2064. AQD’s attempt to demonstrate the reasonableness of its “reasonable progress goals” is illogical and does not pass legal muster. DEQ believes that the State has adequately justified why the URP was unachievable in this planning period. According to 51.308 (d)(1)(i)(B ) of th e Regional Haze Rule “For the period of the implementation plan, if the State establishes a reasonable progress goal that provides for slower rate of improvement in the visibility than the rate that would be needed to attain natural conditions by 2064, the State must demonstrate, based on the factors in paragraph(d)(1)(i)(A) of this section, that the rate of progress for the implementation plan to attain natural conditions by 2064 is not reasonable; and that the progress goal adopted by the State is reason able.” Section 7.6 of the SIP outlines nine reasons as to why the State believes that the progress goals set are reasonable.

Earthjustice E38 General AQD states that it is “more difficult to show improvement in visibility over time in Wyoming than it is in the Eastern state s because the state it starting out so clean”. It does not follow from AQD’s premise, however
, that it should take far longer to achieve natural visibility in Wyoming than other states that face the challenge of greater pollution levels. When comparing Wyoming air to air in the Eastern states, DEQ was trying to demonstrate that it is not as easy to show progress when there are fewer initial visibility impacts . The initial URP does not dictate the total time that it will take to achieve na tural visibility, and it is therefore inappropriate to estimate the total time that it will take Wyoming to achieve natural conditions based on the URP for the first planning period. The uniform rate of progress assumes that identical emission reductions will occur each year in order to achieve natural visibility conditions by 2064, and serves as a guideline to keep states on track. In reality, emission reductions will not occur at a uniform rate for each planning period. Therefore, DEQ is trying to expr ess that in states with higher visibility impacts should be able to achieve the initial URP goal, but may experience the same problem as Wyoming and other Western states when trying to achieve URP in the later stages of the plan when their air becomes “cle aner”.

### 53 Commenter Comment # Section Comment DEQ Response

Earthjustice E39 General AQD also attempts to justify its laggardly progress toward natural visibility by pointing to “[m]ajor reductions in SO 2 emissions” due to the 309 alternative program. DEQ is not attempting to justify its laggardly progress toward natural visibility conditions by pointing out the progress made by the 309 program. The state is permitted to take full credit for SO 2 emissions achieved in the 309 program according to 51.309(g)(20(i): “ ...the State may build upon the strategies imp lemented under paragraph (d) of this section, and take full credit for the visibility improvement achieved through these strategies”. The State is taking full advantage of the 309 program and taking credit for SO 2 reductions achieved by the program. The State has made great strides for reducing SO 2 emissions from the 309 program and found it appropriate to mention in the SIP . As explained in Section 7.6 of the 309(g) SIP, the biggest impediment to reaching natural visibility goals is wildland fires.

Earthjustice E40 BART AQD’s claim that significant NO x emissions reductions will be achieved through BART is unsatisfactory justification for slow visibility improvement, when AQD has failed to require timely implementation of SCR on coal

- fired power plants and failed to require installation of cost

- effective control technologies on oil and gas development activities. The BART determination process has taken longer than expected to complete. It was originally envisioned that BART determination would occur be fore the 309(g) was released. However, since this did not occur as expeditiously as expected, the BART and 309(g) processes are occurring in parallel. Therefore, the DEQ was not able to take credit for or model BART reductions during this planning period . DEQ believes that it is appropriate to include this argument in the demonstration that the progress goals are reasonable.

Specific control strategies for oil and gas sources have not been incorporated into this SIP. The State is waiting for the WRAP Ph ase III report to be released, so that the Division can get a better understanding of how the emissions are distributed and what sources the State should look at controlling.

Earthjustice E41 Reasonable Progress

Goals At Wyoming’s proposed rate of progress, natural visibility conditions will not be reached for more than 100 years in any Wyoming Class I area. Under any definition, this goal is not “reasonable”, particularly given the multiple additional strategies available. Wyoming is not in a unique positio n. Most of the Western states are expressing difficulty achieving the URP goal due to the presence of uncontrollable fires in th e West

. Section 51.308(d) of t he Regional Haze Rule states that “The reasonable progress goals must provide for an improvement in visibility for the most impaired days over the period of the implementation plan and ensure no degradation in visibility for the least impaired days over the same period”. Since there is no degradation in visibility for the 20% best days, this portion of the Rule is satisfied. During the 20% worst days, wildfires are a major contributing factor. Until there is a decrease in wildfires, it will continue to be difficult to achieve URP goals.

Please note that not all reductions were included in the WRAP modeling. The results do not

### 54 Commenter Comment # Section Comment DEQ Response include the BART and long

- term strategy reduction s proposed in this SIP or any other WRAP
SIP s . The WRAP could only include enforceable reductions that were on the books at the time of the last model run.

Earthjustice E42 Better than BART AQD’s 309(g) SIP is insufficient with respect to SO 2 because it fails to include a demonstration that the WRAP alternative program “will achieve greater reasonable progress than would have resulted from the installation and operation of BA RT at all sources subject to BART in the state”. This demonstration is required for all Class I areas with visibility impacts from Wyoming sources, not just Colorado Plateau Class I areas covered by the WRAP alternative program. Neither WRAP nor AQD have demonstrated that the improvements under the WRAP alternative program are better than BART for Class I areas outside of the Colorado Plateau

. The demonstration that the 309 program will achieve greater reasonable progres s than BART is required at the S tate level. Emission reduct ions were calculated on a state

- wide basis, not at each Class I area. This can be seen in the Demonstration that the SO 2 Milestones Provide Greater Reasonable Progress than BART provided i n Appendix E . Visibility was modeled a t all Wyoming Class I areas, and Class I areas in surrounding states. It can be seen in Table 6.2

- 2 of the SIP
, and more extensively in Table 4 of the Demonstration document
, that visibility in all surrounding Class I areas improves on the 20% worst days and improves or remains flat on the 20% best days.

Earthjustice E43 Better than BART According to section 51.308(e)(3) when the “distribution of emissions is not substantially different than under BART, and the alternative measure results in greater emissions reductions...”
, WRAP cannot lawfully comply with the “greater reasonable progress” requirement using the alternative method. The Demonstration that the SO 2 Milestones Provide Greater Reasonable Progress than BART report found i n Appendix E does not take into account new source growth. For sources that have the potential to emit greater than 100 TPY of SO 2 , the 309 program places a cap on all new source growth. There is no such cap placed on the growth of BART sources, which can continue to grow as long as the source meets the permitting requirements. Thus, there will be greater reasonable progress long

- term with the 309 program, but emission reductions are difficult to quantify.

Earthjustice E44 Reasonable Progress

Goals Since Wyoming’s 2018 reasonable progress goals are less than the 2018 uniform rate of progress, Wyoming must evaluate any additional controls to achieve greater progress, including whether additional SO 2 emissions reductions are feasible. If the State’s reasonable progress goa ls are less than the uniform rate of progress, the Regional
Haze R ule requires that the State demonstrate why the goals set are reasonable. It is not a requirement that the State evaluate additional controls. According to 51.308(d)(1)(i)(B) of the Region al Haze Rule
, “For the period of the implementation plan, if the State establishes a reasonable progress goal that provides for slower rate of improvement in the visibility than the rate that would be needed to attain natural conditions by 2064, the State must demonstrate, based on the factors in paragraph(d)(1)(i)(A) of this section, that the rate of progress for the implementation plan to attain natural conditions by 2064 is not reasonable; and that the

### 55 Commenter Comment # Section Comment DEQ Response progress goal adopted by the State is reasonable.” Section 7.6 of the SIP outlines nine reasons as to why the State believes that the progress goals set are reasonable.

Earthjustice E45 BART AQD’s BART determinations for No x emissions are inadequate, because they do not require timely installation of selective catalytic reduction (“SCR”) at Wyoming power plants. As EPA and NPS have noted, SCR is BART for coal

- fired power plants. When determining the appropriate BART for each source, the Division followed Chapter 6 Section 9 from the Wyoming Air Quality Standards and Regulations (WAQSR), as well as EPA’s subpart Y Guidance. Each source underwent permitting and went out for public commenting. DEQ responded to each comment. All comments and responses can be found in the TSD, under Chapter 11 State Responses to BART. Permit applications and analysis can be found in Attachment A of the SIP.

Earthjustice E46 BART AQD improperly relies on installation and operation of BART as part of its long term strategy, rather than requiring immediate BART compliance. Since AQD has determined that SCR is BART for th e se PacifiCorp units, AQD lacks the discretion to extend BART compliance beyond the regulatory deadline. DEQ did not determine tha t SCR is BART for any of the PacifiCorp units. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the WAQSR, as well as EPA’s Subpart Y Guidance. The permit application and DEQ analyse s can be found in Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp . The summary of BART determination for each source can be found on Table 6.4

- 1 of the SIP. According to SIP
S ection 6.4, all BART is to be installed “as expeditiously as practicable, but no later than five years after EPA approval of the state implementation plan revision”.

Earthjustice E47 Oil and Gas The 309(g) SIP does not satisfy regulatory requirements because it includes no measures for even maintaining, let alone reducing, current emissions levels from Wyoming’s oil and gas industry. Wyoming has already evaluated potential control technology and has identified cost effective technologies that could readily be installed on oil and gas exploration and production equipment. DEQ cannot complete the evaluation of oil and gas impacts on visibility until Phase III of the WRAP study has been complete d

. Until the evaluation has been finalized and emissions from oil and gas sourc es are better understood, it is difficult to determine what sources should be controlled. If Wyoming has evaluated any control technology for oil and gas exploration, there is currently no regulation that requires companies to install these control techno logies. The SIP can only include enforceable actions, and until oil and gas operations are better understood, rules and regulations cannot be developed. Therefore, it is necessary for Phase III of the WRAP study to be complete d before the DEQ can begin r egulating oil and gas sources.

Earthjustice E48 Oil and Gas Wyoming states that it does not yet have regulatory authority to require oil and gas operations to install control technology, and contemplates that such a rulemaking could take up to two years. While we appreciate that rulemakings of this nature take time, it is inexcusable that Wyoming has delayed this p rocess even while it has known o f its obligations under the regional haze rule for Before the State can begin rulemaking, the Division must understand what types of oil and gas sources should be regulated. The WRAP Phase III report will contain emissions broken down by source, which will allow the DEQ to determine which sources should be the focus of emission reductions. The Division does encourage oil and gas operators to offset emissions prior to regulatory requirements. Significant reductions are being made in the Upper Green River Basin partially as a result of voluntary reductions. The State currently has interim policies

### 56 Commenter Comment # Section Comment DEQ Response more than a decade. In any event, while AQD lacks regulatory authority to limit emissions from oil and gas activities, the agency should evaluate the potential for voluntary reductions through incentives programs or, as the National Park Service recommended in its October 21, 2009 309(g) SIP comments, encourage ind ustry to offset emissions prior to regulatory requirements. for emissions offsets.

Earthjustice E49 Oil and Gas The AQD is a cooperating agency in numerous environmental review documents that address the visibility impact of oil and gas development in Wyoming Class I areas. Various Environmental Impact Statements have been prepared that include an evaluation of potential mitigation measures. The DEQ is a cooperating agency in the National Environmental Policy Act (NEPA) analysis. However, Environmental Impact Statements are to be used as a decision making tool, not an implementation planning and regulation deve lopment tool. In addition, all information is pre

decisional until a draft document has been released to the public and is not approved until a Record of Decision is released.

Earthjustice E50 Oil and gas At minimum, AQD’s long term strategy must include timelines for completing the oil and gas emissions inventory and finalizing of oil and gas development activities

. The DEQ is not able to provide a timeline for completing the oil and gas emissions inventory. The Division can only provide timelines that D EQ can enforce. The estimated deadline for the report that WRAP has proposed is not enforceable.

PacifiCorp E51 General PacifiCorp supports the emission reduction requirements and time schedule contained in Wyoming’s Regional Haze SIP as those relate to PacifiCorp’s facilities in Wyoming. The State appreciates PacifiCorp’s recognition of the emission control strategies taken by the
Division.

PacifiCorp E52 BART PacifiCorp believes that the emission reduction projects and their timing

- including those described in the Wyoming Regional
Haze SIP

- appropriately balance the need for emission reductions over time with the cost and other concerns of our customers,
our sta te utility regulatory commissions, and other stakeholders. PacifiCorp believes this plan is complementary and consistent with the Wyoming BART and regional haze planning The State of Wyoming appreciates PacifiCorp’s recognition that the State has fulfilled the requirements set forth by the Regional Haze Rule and has also followed Chapter 6
, Section 9 of the WAQSR and EPA’s S ubpart Y Guidance for permitting BART sources.

### 57 Commenter Comment # Section Comment DEQ Response requirements, and that it is a reasonable approach to achieving emission reductions i n Wyoming and other states.

PacifiCorp E53 BART When considering PacifiCorp’s entire fleet of coal

- fired generating units, it is unrealistic to expect the installation of any additional controls on a time schedule any faster than is already contemplated by the proposed Regional Haze SIP. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulations (WAQSR), as well as EPA’s Subpart Y Guidance. Each source underwent permi tting and went out for p ublic comment

. DEQ responded to each comment. All comments and responses can be fou nd in the TSD, under Chapter 11, Summary of FLM (and Other) Comments on BART and State Responses on BART

. The State believes that the BART analysis has been conducted appropriately and all of the requirements stated on the permits, and the appeal decision documents will be DEQ’s enforceable requirements for each source.

PacifiCorp E54 BART Arguments that the cost effectiveness criteria utilized under the BART determinations, in the range of $3,500 to $4,300 per ton of
NO x removed at the PacifiCorp facilities to improve visibility are disproportionate with the health

- based criteria established under many other EPA rulemakings and regulatory progr ams. The EPA’s Appendix Y guidance describes the EPA’s selection of presumptive NO x limits for coal

- fired EGUs, and provides approximate cost levels for meeting the presumptive limits with current combustion controls
, and a somewhat higher cost level for a subset of units that would require advanced combustion controls such as rotating opposed fire air (ROFA). The EPA guidance does not attempt to establish cost thresholds that would be considered unreasonable for a given control technology, nor does it pre sent the approximate costs associated with the presumptive levels as absolute limits above which cost should be deemed unreasonable. The Division established NO x emission limits for BART based on consideration of all five statutory factors in their entire ty, as required by the Appendix Y guidance

.

PacifiCorp E55 Averaging Period PacifiCorp recommends that a standard method be utilized at its four power plants owned and operating in Wyoming to demonstrate compliance with any pound p er hour or pound per million Btu emission limits based on a 30

- day rolling average. PacifiCorp recommends that the Dave Johnston, Wyodak, Jim Bridger and Naughton plants demonstrate compliance with these 30

- day rolling averages based on all valid 1

- hour average
emissions cont ained in the previous 30 calendar days. The following equation describes the recommended method to be used to calculate the pound pe r hour and pound per million Btu
emission rates on a 30

- day rolling average basis: The DEQ has included PacifiCorp ’ s rec ommendation in the SIP. Section 6.5 V has been changed accordingly.

### 58 Commenter Comment # Section Comment DEQ Response

PacifiCorp E56 BART PacifiCorp requests that the description regarding the baghouses for the Dave Johnston (pages 106

- 107) and Wyodak (pages 111

- 112) facilities be amended, consistent with the language set forth in the amended language for the Naughton facility (page 109)

. Th is language has been changed in the SIP

.

PacifiCorp E57 BART Section 6.5 (page 99): change this provision to note that the BART determinations have now been finalized

. This language has been changed in the SIP

.

PacifiCorp E58 BART Section 6.5.4 (page 104): remove the provision which states that the Bridger plant BART permit is under appeal

. This language has been changed in the SIP

.

PacifiCorp E59 BART Section 6.5.6 (page 108): remove the provision which states that the Naughton plant BART permit is under appeal

. This language has been changed in the SIP

.

PacifiCorp E60 BART Section 8.3.3 (page 172

- 173): remove the provision which states that the Bridger plant BART permit is under appeal

. This language has been changed in the SIP

.

Wyoming Outdoor Council E61 General We believe that the current massive amount of technical language that is found in these SIPs is language that very few can really understand, and thus defeats this important underlying purpose and policy. Consequently we ask the AQD to correct The DEQ has strived to present a highly technical subject in a ma nner that is understandable by the general public. Unfortunately, due to the technical nature of the topic, and the rules set forth by the Regional Haze Rule, it is not possible to completely remove all technical language. The Division has posted additio nal background information for the public on the DEQ website:

### 59 Commenter Comment # Section Comment DEQ Response this proble m, and make this important public policy statement regarding regional haze and the protection of iconic Class I areas fully understandable to the public

- at

- large, not just a few specialist s

. http://deq.state.wy.us/aqd/regionalhaze.asp . The additional information is aimed at helping the public understand regional haze and w hat is required by the Rule and Implementation Plan. The SIP contains a Regional Haze Glossary of Visibility Acronyms, Abbreviations, and
Terms in the Technical Support Document to assist in technical language understanding.

Wyoming Outdoor Council E62 General We ask the AQD to fully consider prior comments that we have submitted to it regarding the regional haze rule and implementation of it. All prior comments that were signed and dated and submitted to the DEQ within the assigned commenting periods we re responded to by the Division and can be found in the Technical Support Document. The Division takes every comment seriously and has responded to each one individually. This process can often take a prolonged period of time since the answers must be co nsistent with all stakeholders and presented in one unified document.

Wyoming Outdoor Council E63 General Three sets of comments were submitted by the Wyoming Outdoor Council to the AQD on September 10, 2008 regarding the Green River Works, Westvaco, and Granger trona plant BART permits. Supplemental comments regarding the trona plant BART permits were submitted to the AQD on October 17, 2008. Comments regarding the power plant BART permits were submitted to the AQD on August 4, 2009. In our view, the

c urrent draft SIPs do not make it clear that these prior comments have been fully considered. The New Source Review (NSR) programs respond to all BART related comments. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulations (WAQSR), as well as EPA’s Subpart Y Guidance. Each source underwent permitting an d went out for public comment . DEQ responded to each comment. All comments and responses can be found in t he TSD, under Chapter 11
, Summary of FLM (and Other) Comments on BART and State Responses on BART

. Permit applications and DEQ’s analysis of each permit can be found in Attachment A of the SIP

at: http://deq.state.wy.us/aqd/regionalhaze.asp

. All prior comments that were signed and dated and submitted to the DEQ within the assigned commenting periods were responded to by the Division and can be found in the Technical Support Document. The DEQ tak es every comment seriously and has prepared an appropriate response for each comment received.

Wyoming Outdoor Council E64 General Comments regarding the first draft 309(g) SIP were submitted to the AQD on October 26

- 27 2009. Comments were also submitted to the AQD on October 19, 2009. In our view, the current draft SIPs do not make it clear that these prior comments have been fully considered. All of these noted comments were received in the appropriate commenting period, and have been addressed by the DEQ in this SIP revision. The DEQ has taken each comment seriously and have prepared a response to each comment. All responses can be found in the Technical Support Document. The comments that are 309

- related take a little longer to answer since they must be reviewed by all of the 309 states, and consistent conclusion s must be developed between all stakeholders. However, all responses to 309 comments are also included in the Technical Support Document.

### 60 Commenter Comment # Section Comment DEQ Response

Wyoming Outdoor Council E65 General Forest fires are not new. They have been occurring since time immemorial. While it is generally recognized that we have recently been in a period of heightened forest fire activity (and perhaps intensity) due to drought and past forest management practices, this curr ent upsurge probably will not last forever. Thus, claims that forest fires will prevent us from achieving natural visibility conditions could be overstated, at least in the medium

- to

- long

- term. The AQD should recognize this long

- term eventuality and put in place a long

- term strategy that recognizes the possible future diminishment of forest fire activity. We ask the AQD to consult closely with the Forest Service on this issue

the Forest Service is a Federal Land Manager and thus should be intimately invo lved in the development of this SIP

- so as to ensure that its clams regarding forest fires are supported by the best available science. The DEQ recognizes that forest fire activity changes through time and is not implying that achievement of natural visibil ity conditions is not possible in the life time of the SIP. The State attributes the inability to meet this planning period’s URP goals primarily to forest fires. Reasonable progress goals will be re

- evaluated in subsequent reporting periods, and if a dec rease in forest fire activity is seen
, then it may be possible to meet the URP goals for the given period. Section 51.308(d)(3) states “ The long term strategy must include enforceable emissions limitation, compliance schedules, and other measures as neces sary to achieve the reasonable progress goals established...”

. According to this section of the Ru le, the State can only set long

- term strategies that are enforceable. A decrease in forest fires is not enforceable or quantifiable, but rather a guess that a ctivity may decrease in the future. Therefore, possible diminishment of forest fires cannot be included in the long

- term strategy. The State has consulted closely with the Forest Service, recognizing the agency as a Federal Land Manager
, and will continu e to do so in future SIPs

.

Wyoming Outdoor Council E66 Forest Fires If the claims in the 309(g) SIP that natural visibility conditions are approximately 6.0 dv on the worst visibility days are incorrect and that the current conditions on the worst visibility days (approximately 11.5) are more in line with what is possible given forest fires (this is the implication of AQD’s claims forest fires prevent achievement of natural conditions), the SIP should be revised to reflect this changed understanding

. The EPA has estimated the natural conditions based on factors such as mass components, IMPROVE methodology, relative humidity data (used to develop relative humidity adjustments), and error factors. The EPA developed a detailed document on how natural

c onditions were established: http://www.epa.gov/ttn/oarpg/t1/memoranda/rh_envcurhr_gd.pdf . Natural condition development as it relates to fire can be found in Section 1.14. Natur al emissions from fires were taken into account through estimates based on compilations of natural versus man

- made levels, ambient measurements in remote areas, regression studies and applied uncertainties. The EPA relied heavily on the National Acid Prec ipitation Program (NAPAP) developed in 1990 to establish natural visibility conditions for the Regional Haze SIP. The following website provides a detailed description of the NAPAP program: http://www.epa.gov/airmarkets/resource/docs/NAPAP.pdf

. Natural visibility conditions are an estimate, and are difficult to determine. It is expected that

### 61 Commenter Comment # Section Comment DEQ Response

EPA will revise the natural conditions estimate in future SIP revisions when there is a better understanding of natural visibility conditions, and estimation methodologies.

Wyoming Outdoor Council E67 General As noted in the October 2009 comment, no matter what the impact of forest fires is on visibility, they only occur for about six months of the year, often more like four months per year, so in much of the year forest fires are of little issue relative to visibility impacts. Thus, the 309(g) SIP should be constructed from this perspective. Section 51.308(d) of t he Regional Haze Rule states that “ T he reasonable progress goals must provide for an improvement in visibility for the most impaired days over the period of the implementation plan and ensure no degradation in visibility for the least impaired days over the same period ”. I n the case of the best days, modeling demonstrates no further degradation of visibility. The worst days occurred in the summer months. Therefore, focusing on correcting the winter months will have no impact on the results of the worst days modeling

. The worst days can b e seen in the modeling section: http://vista.cira.colostate.edu/TSS/Results/HazePlanning.aspx

BART

- eligible sources identified in the SIP are required to control emissions year ro und, and the Division is confident that BART implementation will have significant visibility impairment
im provements in both the summer and winter months.

Wyoming Outdoor Council E68 Oil and Gas Development The 309(g) SIP does not specifically plan to take any additional actions to control emissions from the oil and gas industry. We believe there is already in place more than enough information that dictates the need to take further action under the SIP. DEQ is aware that there is an abundance of oil a nd gas related information. However, there is not a clean inventory available that contains information compiled using a systematic method. WRAP is working on such an inventory right now in Phase III of its project.

Oil and gas inventories are complicate d to quantify. It is true that the DEQ has access to information for various small pieces of the process. However, to compile a complete inventory, every source must be looked at right down to the wellhead level. This includes the emissions associated w ith drilling and completing each well, which in itself is very complex. To name a few, the drilling and completion process alone has emissions associated with trucking trips for various fluids and pieces of equipment, drill rigs, completion rigs, wireline s, and fraccing equipment. Each well has different emissions associated with each activity. After the well is drilled and completed, the production process begins and there will be emissions associated with various pieces of production equipment such as tanks, flares, dehy units, compressor stations, fluid trucking, and pipeline losses. To account for all of these emissions, some of the things that must be known are how many pieces of production equipment are in the state, what types of controls each uni t has, and how much oil and gas is being produced

### 62 Commenter Comment # Section Comment DEQ Response from each facility. These are only some examples of the complexity of an inventory development for oil and gas sources. A complete inventory will have t o look at many more aspects than what was just outli ned.

The State of Wyoming is making great strides for identifying and quantifying sources and emissions from new fields. However, it is much more difficult to quantify emissions associated with older fields in the state. In addition, the Division has sta rted collecting inventories for oil and gas sources. The WRAP study will assist the State in understanding all of the sources that need to be evaluated.

Wyoming Outdoor Council E69 Oil and Gas The Bureau of Land Management (BLM) has prepared a number of Environmental Impact Statements (EIS) in recent years that address the visibility impacts of oil and gas development in Wyoming Class I areas. The AQD was designated as a “cooperating agency” in the preparation of the EIS, meaning that the AQD was a full party to these analyses, and the records of decision (ROD) that were put in place to implement them. The AQD should adopt provisions from the RODs. For example, operators are to comply with AQD Best Available Control Technology (BA C T) standards. The BLM Environmental Impact Statements are to be used by the BLM as a decision making tool, not an implementation planning and regulation development tool. Although the AQD is a cooperating agency, all of the information is pre

- decisional until a draft document has been released to the public and is not approved until a Record of Decision (ROD) is released. The ROD can only be applied to the Federal land within the project boundaries. Therefore,
agree ments made in the ROD cannot be applied state wide. All operators must comply with DEQ ’ s Best Available Control Technology (BACT), not only the ones identified in the Pinedale ROD. Chapter 6
, Section 2 of the WAQSR contains a permitting guidance, includi ng BACT requirements for sources statewide.

Wyoming Outdoor Council E70 Oil and Gas Another area where reduction of the already well documented impacts of the oil and gas industry on visibility in Class I areas might be achieved is through the EPA’s upcoming revision of the New Source Performance Standards and National Emissio ns Standards for Hazardous Air P ollutants in the oil and gas industry. The AQD should commit to assisting the EPA in revising these regulations, and the 309(g) SIP should make

e nforcement of them a component of the SIP. The WAQSR contains chapters that include New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAPs). The State of Wyoming adopts portions of each EPA standard. However, if the standard is not adopted, then the EPA regulates the sources contained in the category. Thus, each regulation is enforceable at the State or Federal level. There are a num ber of oil and gas related NSPS s that Wyoming has adopted such as s tandards of performance for petroleum refineries, storage vessels for petroleum liquids, VOC equipment leaks in petroleum refineries and natural gas processing plants, and onshore natural gas processing SO 2 emissions. A full list of the adopted NSPS stand ards can be found in Section 8.2.1.3 of the SIP, and the full standards and regulations adopted by Wyoming can be found in Chapter 5
, Section 2 of the WAQSR. There are also a

### 63 Commenter Comment # Section Comment DEQ Response number of oil and gas sources regulated under the Wyoming NESHAP program such as petroleum refineries, oil and natural gas production facilities and gasoline distribution facilities. A full list of the adopted NESHAP standards can be found in Section 8.2.1.4 of the SIP, and the full standards and regulations can be found in WAQSR Cha pter 5 , Section 3, and Chapter 6
, Section 5.

The State and Federal rulemaking processes are performed separately. Other than commenting during the appropriate commenting periods, the DEQ cannot assist the EPA in the Federal rulemaking process. The State does undergo periodic revisions to the NSPS and NESHAP sections of the Wyoming rules, and will incorporate by reference at that time any new EPA standards and regulations that the Division determines to be appropriate for State regulation.

Wyoming Outdoor Council E71 BART There are at least five point sources of air pollution that significantly affect visibility in the Bridger and Fitzpatrick Wilderness Area s , and the AQD has full authority to regulate them: the Naughton and Jim Bridger power plants and the Granger, Westvaco, and Green River Works trona plants. Thus, the SIP should focus special attention on dealing with haze causing pollution generated by these sources of pollution because it could lead to direct and me aningful improvement of visibility in these discrete, well defined Class I areas. In particular, the AQD should require Selective Catalytic Reduction (SCR) as a nitrogen oxides pollution con trol measure at these plants. All of the listed point sources ha ve been analyzed by the BART process. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulations (WAQSR), as well as EPA’s Subpart Y Guidance. Each source under went permitting and went out for public comment . DEQ responded to each comment. The public hearings for Granger, Westvaco, and Green River Works were all held in Rock Springs
, WY on September 11, 2008. The public hearing for Jim Bridger was held on Augu st 4, 2009 in Rock Springs
, WY. Finally, Naughton’s public hearing was held on August 4,
2009 in Kemmerer
, WY. All comments and responses can be found in the TSD, under Chapter
11 , Summary of FLM (and Other) Comments on BART and State Responses on BART

. Permit applications and analyse s can be found in Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp

.

Wyoming Outdoor Council E72 BART Relying solely on the milestones and backstop trading program is only appropriate when it “will result in greater reasonable progress than source

- specific BART in all Class I areas, including Bridger and Fitzpatrick, not just the sixteen (16) on the Colora do Plateau”. Thus, BART relative to sulfur dioxide pollution should be required for these five large sources of air pollution, in The State has modeled visibility in the additional non

- Colorado P lateau Cla ss I area monitor locations in Wyoming and s urrounding states. Table 6.2

- 2 demonstrates visibility broken down by sulfate ext inction only. It can be seen in this table that all Class I areas show visibility improvement for the worst days, and no degradation in visibility for the best days, thereby meeting the requirements outlined in the Regional Haze Rule. In addi tion, Table 6.2

- 1 outlines the R egional SO 2 Emissions and Milestone R eport summary. This table demonstrates that the 309 states have experienced significant SO 2 reductions and have more than exceeded the goals

### 64 Commenter Comment # Section Comment DEQ Response addition to compliance with the milestone program, so as to achieve greater reasonable progress to ward the natural visibility goal at the Bridger and Fitzpatrick Wilderness Areas

. set by the program

.

The R egional Haze Rule requires the above demonstration , as well as a demonstration that the milestone s provide greater reasonable progress than BART. This demonstration can be found i n Appendix E, Demonstration that the SO 2 Milestones Provide Greater Reasonable Progress than BART. As long as this demonstration is performed, u nder t he Regional Haze Rule, EPA allows the S tate to take credit for any SO 2 reduction achieved in S ection 309, as stated in 51.309(g)(i): “ In developing long term strategies pursuant to 51.308(d)(3), the state may bui ld upon the strategies implemented under paragraph 9 ( d) of this section, and take full credit for the visibility improvement achieved through these s trategies. ” The rule does not require that SO 2 sources undergo further reduction to achieve greater reason able progress toward natural visibility.

Therefore, the State believes that all requirements of the Regional Haze Rule as it relates to the 309 strategies for meeting visibility goals have been met and the SO 2 sources do not require further analysis.

Wyoming Outdoor Council E73 General Current visibility on the worst days is 11.1 dv, the needed improvement to be the “glide slope” would be 10.0 dv, yet the AQD is only planning to achieve visibility quality of 10.6 dv by 2018. But it seems apparent that considerably more improvement in visibility in these Class I areas should be achieved if the AQD focused greater pollution control efforts on the five sources of nitrates and sulfates located in Wyoming that contribute very significantly to this visibility degradation. The WRAP states have stressed that the uniform rate of progress is not achieved in any of the
W estern states because there are too many uncontrollable sources of emissio ns impacting visibility in the W est, overwhelming the controllable source s. O rganic carbon from wildfires is the single biggest contributor to visibility impairment in the West

. Section 51.308(d) of t he Regional Haze Rule states that “ The reasonable progress goals must provide for an improvement in visibility for the most impa ired days over the period of the implementation plan and ensure no degradation in visibility for the least impaired days over the same period ”. Since there is no degradation in visibility for the 20% best days, this portion of the Rule is satisfied. Dur ing the 20% worst days, wildfires are a major contributing factor. Therefore, without the ability to control wildfires, it is difficult to demonstrate enough reasonable progress to reach the URP goal.

The State believes that the appropriate BART analysis has been conducted on the five BART

specific sources addressed by these comment s

. When determining the appropriate BART for each source, the Division followed Chapter 6
, Section 9 from the Wyoming Air Quality Standards and Regulat ions (WAQSR), as well as EPA’s S ubpart Y Guidance. Each source

### 65 Commenter Comment # Section Comment DEQ Response underwent permitting and went out for public comment . DEQ responded to each comment. The public hearings for Granger, Westvaco, and Green River Works were all held in Rock Springs
, WY on September 11, 2008. The p ublic hearing for Jim Bridger was held on August 4, 2009 in Rock Springs
, WY. Finally, Naughton’s public hearing was held on August 4, 2009 in
Kemmerer , WY. All comments and responses can be found in the TSD, under Chapter 11
, Summary of FLM (and Other) Comments on BART and State Responses on BART

. Permit applications and analysis can be found in Attachment A of the SIP at: http://deq.state.wy.us/aqd/regionalhaze.asp

.
Also note that not all reductions were included in the WRAP modeling. The results do no t include the BART and long

- term strategy reduction s proposed in this SIP or any other WRAP
SIP s . The WRAP could only include enforceable reductions that were on the books at the time of the last model run. These regional model runs take many months to set up and run.

Wyoming Outdoor Council E74 URP Goals Table 7.2

- 1 in the 309(g) SIP shows that natural visibility conditions will not be reached until many years after the goal of reaching natural conditions by 2064. This raised significant questions regarding whether the State of Wyoming is pursuing reasonable progress towards natural visibility conditions. Wyoming is not in a unique position. Most of the Western states are expressing dif ficulty achieving the URP goal due to the presence of u ncontrollable fires in the West

. Section 51.308(d) of t he Regional Haze Rule states that “The reasonable progress goals must provide for an improvement in visibility for the most impaired days over th e period of the implementation plan and ensure no degradation in visibility for the least impaired days over the same period”. Since there is no degradation in visibility for the 20% best days, this portion of the Rule is satisfied. During the 20% worst days, wildfires are a major contributing factor. Until there is a decrease in wildfires, it will continue to be difficult to achieve URP goals.

It is important to note that not all reductions were included in the WRAP modeling. The results do not include the BART and long

- term strategy reduction s proposed in this SIP or any other
WRAP SIP s . The WRAP could only include enforceable reductions that were on the books at the time of the last model run.

### 66 Commenter Comment # Section Comment DEQ Response

Wyoming Outdoor Council E75 Reasonable Progress

Goals The AQD states that tremendous progress has been made in the past controlling sulfur dioxide emissions. While this may be true, and we appreciate the AQD’s efforts in this regard, this does not change the fact that if visibility is still impaired

- which it
is

- then additional reductions must be made. The DEQ is trying to express that even though the State experiences the obstacle of visibility impairment due to forest fires, there has been significant progress made in the areas that are within the Division ’ s con trol. The State has addressed how further red uctions can be made in the Long

- Term Strategy section of the SIP.

Wyoming Outdoor Council E76 Reasonable Progress

Goals The AQD says that since “the state is starting out so clean” it essentially is reasonable to not expect more; compared to the East Wyoming is pretty good, so let ’ s not ask for more. We find this statement offensive a n d ask that it be removed from the
SIP. DEQ is not in any way trying to imply that the State “should not expect more ”. DEQ is simply trying to demonstrate that it is not as easy to show progress when there are fewer initial visibility impacts. It is much easier to show increased original progress when there are greater impacts. In addition, there is a large differenc e in vegetation and meteorologi cal conditions between the East and the W est. For example, in comparison to the E ast , the C lass I areas in Wyoming are located in more heavily forested areas, and therefore more natural fires occur within the C lass I area pr oximity. The low humidity in the West also allows for a more noticeable difference in the visibility when such an event occurs. The DEQ is not making excuses for not achieving URP goals and the Division does take the goal very seriously. The DEQ simply wanted to explain in the SIP why oth er states such as those in the E ast may be able to meet the URP in the initial phase, while Wyoming and other Western states were not.

Wyoming Outdoor Council E77 Long

- Term Strategy The AQD evaluated non

- BART sources of emissions for potential controls so as to comply with the regional haze rule, and to meet its goal. We believe that delaying pollution controls for these sources for nearly ten years is not reasonable and should be revisited by the AQD. The AQD could ini tiate any needed rule making now, or in the near future, and not wait nearly ten years to do this. The DEQ does not claim to wait until the next rev ision to begin the rule making process. Rather, the Division is stating that the State currently does not hav e the authority to regulate these sources at this time, and that rules need to be developed in order to do so. The next SIP revision will be the first opportunity to control these sources through rules that may be in place by the next revision. Oil and g as rulemaking will not begin until the WRAP Phase III report has been complete, and the Division has a better understanding of what source types need to be controlled.

### 67 Commenter Comment # Section Comment DEQ Response

Wyoming Outdoor Council E78 BART The AQD claims that it is appropr iate to essentially give PacifiC orp a break on pollution control requirements because it owns several large pollution sources in several states, and it could be difficult for the company to manage regional haze rule compliance on all of these plants at the same time. The DEQ is not giving PacifiCorp a “break on pollution control requirements”. The State initially staggered the implementation deadline of the BART requirements in order to provide PacifiCorp with the appropriate time limit that would allow the installation of th e equipment at all of the 19 sites. However, the SIP has undergone revisions, and the permit has undergone an appeal process. The SIP now states that PacifiCorp shall install and operate the required BART “ in accordance with the Division’s BART determina tion, and conduct the required initial performance tests to demonstrate compliance as expeditiously as practicable, but no later than five years after EPA approval of the state implementation plan revision ”.

Wyoming Outdoor Council E79 Long

- Term Strategy Unlike many pollutants where the AQD is projecting reductions in emissions, dust is projected to increase fairly dramatically. Yet as best as we can determine the AQD is not planning to take any steps to control this increase in haze causing dust. Most o f this dust will likely be created from dirt roads and construction activities. At a minimum the AQD should commit to investigating and if needed
, putting in place requirements for the use of best managements practices to control this dust. The State of W yoming has implemented a number of programs to reduce PM emissions. The first is a nonattainment SIP for the C ity of Sheridan which addresses four PM 10 control measures. The second is a Natural Events Action Plan which is aimed to protect public health
i n th e Powder River Basin where wind

- generated dust results in 24

- hour NAAQS exceedances. Descriptions of these two programs can be found in Sections 8.2.1.7.1 and 8.2.1.7.2
, respectively.

Wyoming ’s Air Quality Standards and Regulations (WAQSR) Chapter 3
, Section 2
, contains Emissions Stan dards for Particulate Matter. Specifically, Chapter 3
, Section 2(f)
, prescribes measures to ensure the control of fugitive dust emissions during construction or demolition activities, handling, storage, and transporting of materials and agricultural practices. Further discussion on measures taken to mitigate construction dust can be found in Section 8.2.2 of the SIP.

Wyoming Outdoor Council E80 BART The AQD has certified that the Granger trona plant is one of a small group of sources that is causing visibility impairment (1.73 dv) at the Bridger Wilderness Area. Thus, under the RAVI rule the AQD must initiate BART permitting for this trona plant, and such permitting should include sulfur dioxide controls as well as
ni trogen oxides and particulate matter controls. The DEQ does not believe that the trona plant should be grouped with other surrounding sources. Summing the 98 th percentile modeled visibility impacts for separate facilities is not an accurate portrayal of c ombined impacts because the individual impacts may occur at different locations (receptors) and during different 24

- hour time periods. Moreover, the visibility impacts from BART

- eligible sources are to be determined separately. As stated in the EPA ’s App endix Y to part 40 CFR 51

- Guidelines for BART Determinations Under the Regional Haze Rule , relative to the use of the CALPUFF model for BART determinations, “ W e believe that CALPUFF is an appropriate application for States to use for the particular purposes of this rule, to determine if an individual source is reasonably anticipated to cause or contribute to

### 68 Commenter Comment # Section Comment DEQ Response impairment of visibility in Class I areas, and to pred ict the degree of visibility improvement which could reasonably be anticipated to result from the use of retrofit technology at an individual source. We encourage States to use it for these purposes. ”

EPA E81 BART The BART determinations relied on two documents that need to be submitted as part of the SIP: 1) the BART application submitted by the BART sources; and 2) the analysis of the BART application performed by the State

. These documents have been included as Attachment A in the SIP.

EPA E82 Long

- Term Strategy The control measures identified in the four factor analysis need to be included and made enforceable as part of the long

- term strategy , and the State needs to provide a justification as to why those control measures are not reasonable in the context of the four factors. The State has provided an evaluation of the Control Strategies for the four

- fac tor analysis as part of the long

- term strategy in Section 8.3.4. DEQ explains, “ the Air Quality Administrator cannot, per Wyoming Statute 35

- 11

- 20 2, establish emission contr ol requirements except through S tate rule or regulation. Furthermore, the Wyoming statute requires the Administrator to consider the character and degree of injury of the emissions involved. In this case, visibility modeling wo uld be required to assess the degree of injury caused by the emissions. Modeling is not available at this time to determine impacts from emission reduction. The S tate believes it has taken a strong and reasonable first step in identifying potential contr ibutors to visibility impairment, and that the next step of creating an appropriate rule or regulation will be accomplished in the next SIP revision. The visibility progress was designed as a long

- term program going out to 2064”.

EPA E83 Long

- Term Strategy Any emission limitations or control measures that the State is taking credit for under reasonable progress need to be federally enforceable. In draft SIP section 8.2.6, it states “Wyoming has ensured that all existing emission limitations and control

meas ures, for which the State of Wyoming is responsible, used to meet reasonable progress goals, are enforceable at the State level through the Wyoming Air Quality Standards and Regulations (WAQSR) or State issued permits. Once EPA approves this SIP, these me asures will be federally enforceable”. It is not clear what measures the State is referring to. The State needs to specify the particular regulations that are not currently The portions of the SIP that are currently not federally enforceable, but will be after the SIP approval are the BART determin ations, summarized in Table 6. 4

- 1 and the lo ng

- term strategy commitments for the Laramie River Station and Jim Bridger Power Plant BART facilities, found
in Section 8.3.3.

Section 8.2.6 has been revised to read the following: “ Wyoming has ensured that all existing emission limitations and control measures, for which the State of Wyoming is responsible, used to meet reasonable progress goals are enforceable at the State level through the Wyoming Air Quality Standards and Regulations (WAQSR) or State

- issued permits. Many of the actions
i ncluded in the SIP are already federally enforceable. However, BART permit conditions and long

- term strategy commitments for the Laramie River Station and the Jim Bridger Power Plant

### 69 Commenter Comment # Section Comment DEQ Response federally enforceable that will become federally enforceable. These regulations would have to be proposed as part of the SIP, submitted to EPA, and be approved as part of the SIP. are currently only enforceable at the State level. Once EPA approves th is SIP, these measures will be federally enforceable. The BART determinati ons are summarized in Table 6.4

- 1 and the long

- term strategy commitments can be found in Section 8.3.3.”

EPA E84 Reasonable Progress The U.S. EPA commented that the DEQ has included NO x controls for the LRS in the Regional Haze SIP that will be implemented under reasonable progress and not under BART. The EPA is concerned about this proposed approach, and will communicate any concerns to the State when the EPA’s evaluation is complet e. The AQD acknowledges the comment.

EPA E85 Long

- Term Strategy EPA’s regional haze rule does not allow for commitments such as those under Section 8.3.4 to implement strategies at some later date that are identified under reasonable progress or for the state to take credit for such commitments. Lacks of authority or information are not valid reasons to delay implementation of controls under reasonable progress. As mentioned in the SIP, the DEQ does not currently have the regulatory authority to implemen t the controls ide ntified in the four

- factor analysis. However, the State commits to making changes going forward. The first planning period has identified sources that require further regulations, and the State is committed to reductions in the next SIP revision.