INREPLY REFERTO: I 

# United StatesDepartmentoftheInterior

FISHANDWll.DLIFE SERVICE NationalWildlifeRefugeSystem BranchofAirQuality 7333 W. JeffersonAve., Suite 375 Lakewood, CO 80235-2017 September IS, 2008

N36l5 (2350)

David Finley, Administrator Air Quality Division Wyoming DepartmentofEnvironmental Quality 122 W. 25t11 St. Herschler Bldg. 4 W Cheyel1l1e, Wyoming 82002

DearMr. Finley:

TheU. S. Fish and Wildlife Service (FWS) andtheNational Park Service (NPS) are in receipt of two Best Available Retrofit Technology (BART) determinations developed for the FMC Wyoming Corporation,Westvaco Facility and the General Chemical Green River Works, along with the Wyoming DEQ analysis of each BART determination. We have completed a preliminary review, and provide comments in the enclosures to this letter regarding the BART determinations for these facilities. The BARTpermitprocess is not asubstitute for the Regional Haze SIP adoption and review process, and we may have additional comments during the public commentperiod. A 60-day consultationperiod onthe RH SIP revision should beprovidedto !he Federal Land Managers (FLMs) priorto apublic hearing.

We are also in receipt ofcompany-developed BART proposals for eleven Electric Generating Units in Wyoming. Since we do not yet have the Wyoming DEQ analysis of these BART proposals, we are not commenting on those at this time. We respectfully request that the FLMs receive a 60-day commentperiod afterthe DEQ analyses become available.



### TAKE**PRIDE"~ lNAMERICA~** 2

We appreciate your efforts inmanaging and reviewing the BART program for Wyoming, and we thank you for the oppOliunity to comment. Please accept an invitation to discuss our comments by conference call as necessary at your convenience. If you have any questions on these comments, please contact Tim Allen (FWS) at (303) 914-3802, or Bruce Po1kowsky (NPS) at (303) 987-6944. Sincerely,

SandraV. Silva, Chief FWS Branch ofAir Quality

Enclosures (2)

cc: CallieVidetich USEPA Region 8 1595 Wynkoop St., 8P-AR Denver, Colorado 80202-1129

Rick Coleman USFWS Region 6, Refuges 134UnionBlvd Lakewood, Colorado 80228 Sincerely,

# ~l:tr:mcf /NPS AirResources Division

### Enclosure 1 Comments on Two Wyoming BART Determinations FMC Wyoming Corporation, Westvaco Facility, Boilers #4, #6 

### and #7 

### September 15,2008

The BART determinationwas generally well developed. Boiler#4 is a gas-fired boilerthathas a NOx emission limit of0.23 Ibs/mmBtu and these emissions are restricted through "combustion air control." Coal-fired boilers #6 and #7 are currently controlled with "combustion air control" for NOx, awet alkaline scrubberfor S02 andparticulate matter (with a 50% flue gas bypass) and
an electrostaticprecipitator (ESP) forparticulate matter. Analysis was provided for S02 control alternatives in Table 5-2 ofthe Best Available Retrofit Technology Analysis for Sources Subject to BART, FMC Wyoming Corporation's Westvaco Facility, dated March 5, 2007 (FMC's BART determination). Option I, Scrubber Upgrade ($1,066,982 Annual Cost, 6,993.2 tons of S02 reduced, $183/ton, $1O,564,176/deciview) was comparedto Option 2, ScrubberUpgrade & StackReheat ($3,513,039 Annual Cost, 5,827.6 tons ofS02 reduced, $502/t011, $8,344,51O/deciview). Ultimately, FMC selected, and the Wyoming DEQ agreed to Option I as BART. However, the BART Guidelines state that "

... large capital costs for a control option alone would not preclude selection of a control measure if large ernissions reductions areprojected. In such acase, low orreasonable cost effectiveness numbers may validate the option as an appropriate BART alternative irrespective ofthe large capital costs." I Inthis context, Option 2 (eventhoughthe annual costis higher than Option 1) delivers
a cost effectiveness of only $502/ton. This cost-effectiveness is considered very reasonable when compared to all other BART reviews performed by the Federal Land Managers (FLMs)2 Two examples are:

• Tennessee Eastman in Kingsport, TN, has proposed to add S02 scrubbers at a cost of $3,000

- $4,000 per ton to reduce impacts on visibility at Great Smoky Mountains National Park.

• GeorgiaPacific inBig Island, VA, has proposedto add S02 scrubbers at acost of$4,000 pertonto reduceimpacts onvisibility attheJames RiverFace Wilderness Area. In terms ofcost-effectiveness relative to visibility improvement ($/dv), Option 2 also meets that criterion at $8,344,510 per deciview. This value is consideredreasonable giventhat GreatRiver Energy is proposing to add a dry scrubber/baghouse combination to reduce S02 at its Stanton Unit#1 in North Dalmta with a cost-effectiveness ofimproving visibility at Theodore Roosevelt National Park of $14.8 million/dv. Therefore, the FLMs propose that the most reasonable assumptionis the adoption ofOption2as BARTfor S02. Regarding S02 the Wyoming DEQ did not require FMC to install controls, but required that it patiicipate in the Western Backstop Sulfur Dioxide Trading Program. The Bridger Wilderness Area is not one of the 16 Colorado Plateau Class I Areas considered by the Grand Canyon Visibility Transpoli Commission to be under this trading program. Therefore, S02 controls of the Section 309 sources should be evaluated and documented as to the effects on the Section308
areas.
The FLMs' analysis for a NOx control alternative (based on Table 6-3 of FMC's BART determination) is similar to the above discussion for S02. NOx Option 1, Low NOx Burners(LNB) with Over-fire Air (OFA) ($826,290 Almual Cost, 3,418.8 tons of NOx reduced, $242/ton, $2,582,157/deciview) was compared to Option 2, 

### LNB/OFA & SNCR ($2,563,703 Annual Cost, 3,807.2 tons ofNOx reduced, $673/ton, $6,818,358/deciview), Ultimately, FMC selected Option 1 as BART and the Wyoming DEQ agreed, Again, the BART Guidelines3 provide that the most inexpensive alternative should not necessarily be the chosen alternative. As long as a control alternative that delivers additional visibility benefits remains within a costeffective range, that alternative may be validated as being BART. Option 2 delivers a very reasonable costeffectiveness of

### $673/ton. Inpresenting reasonable ranges for cost-effectiveness the preamble to the BART Guidelines states that the presumptive NOx limits for large EGUs range from $100

- $1,000 per ton.4 Although the FMC boilers are not affected by the presumptive limits for large Electric Generating Units (EGUs), the cost structurepresented inthe preamable mightbe generally less expensive on a costperton basis than would be expected for smaller boilers. In terms ofcost-effectiveness relative to visibility improvement, Option 2 at $8,344,510 per deciview is believed by the FLMs to be reasonable. Therefore, the FLMs propose thatthe mostreasonable assumption is the adoptionofOption 2 as BARTforNOx•
The procedure outlined in the BART Guidelines demonstrates control alternatives for a

### single pollutant being compared in order to determine the most cost-effective control for that given pollutant. The value ofusing single pollutant analysis comes from the universe of cost data available for comparison purposes. FMC's BART determination in Table 7-6 developed combinations ofS02 and NOx control alternatives (Alternatives I

- 4). As noted above there is
no provisioninthe BART Guidelines to analyze control alternatives by creating composite costs for various combinations as a means to malce the ultimate BART selections. Nevertheless, even Alternative 4 (Scrubber Upgrade with reheat, 

### LNB/OFAlSNCR) can be accomplished for 

### $563/ton5 and $8,256,442/deciview. Those cost-efficiencies fall within a reasonable range as provided in the BART Guidelines as discussed above. Therefore, the FLMs propose that the mostreasonable assumption is the adoption ofAlternative 4 as S02 andNOx BART (which is a combination of the S02 and NOx choices noted in the above two paragraphs), especially if visibilityimpacts onboththe Bridger and FitzpatrickWilderness Areas are considered.

The next-to-last paragraph of Section 7.2 ofFMC's BART determination compares visibility improvement ofthe control alternatives to 0.5 deciviews in an effOli to marginalize the visibility improvementprojected to result from those control alternatives. The Wyoming DEQ embraces this line ofthinking in its proposed BART Determination. This is a misuse ofthe Division's
own guideline value of0.5 deciviews. This value is used only to confirm that a BART-eligible facility "contributes" to visibility impairment (defined as a visibility impact greater than 0.5 deciviews at a Class I area) so as to become subject to perform a BART determination6 It is inappropriate to use the value to evaluate the perceptibility ofvisibility improvement due to installation ofcontrol equipment. Specifically, the last paragraph ofSection 7.2 ofFMC's BART determination asserts that there would be "no perceptible difference" between Alternative 1 and Alternative 4 in terms of visibility improvement at the nearest Class I area and again the Wyoming DEQ supports this position. It is incorrectto dismiss a control strategy on the basis that the resulting improvement is notperceptible or significant. EPA states in the preamble to its BART Guidelines that, "Even though the visibility improvement from an individual soW'ce may not be perceptible, it should still be considered in setting BART because the contribution to haze may be significantrelativeto other source contributions in the Class I areas. Thus, we disagree that the degree of impairment should be contingent upon perceptibility. Failing to consider less-than-perceptible contributions to visibility impairment would ignore the 

### CANs intent to have BART requirements apply to sources that contribute to, as well as cause, such impairment." 7 Regional haze is a cumulative regional issue with numerous sources contributing to the overall level of haze and therefore controls on a single source cannot be expected to resolve the haze issue. Nevertheless, small increments ofvisibility improvement at cost-effective rates from multiple
sources will result in cumulative visibility improvement. This misinterpretation led the Wyoming DEQ to propose only combustion controls as BART, even though SNCR remains to be acost-effective alternative as discussed above.

FMC states that threepercent 01' less ofthe lightextinction atthe BridgerWilderness Areais due to emissions from gas-fired boiler#4 (see Table 3-4) and for this reason a BART determination
was not performed. There is no exemption in the BART Guidelines from performing a NOx BART determination for this unit. Section 2.1 ofthe FMC BART determination is not specific in describing the "combustion air control" existing onthis unit and the NOx control efficiency is not stated. Cost-effective NO, combustion control alternatives can often be installed and they shouldbe analyzedinthis BART determination.

I See 40 CFR Part 51, Appendix Y. The U.S. Environmental Protection Agency finalized its BARTGuidelines onJune 15,2005, andpublishedthepreamble and final ruletextinthe Federal Register on July 6, 2005. The rulemaking action added Appendix Y to Part 51, titled "Guidelines for BART Determinations Under the Regional Haze Rule." See Section IV.DA.STEP 4.g.

2 The term "Federal Land Managers" and acronym "FLMs" refer to the U. S. Fish and Wildlife Service and the National Park Service, the Department of the Interior agencies tasked with protection ofCleanAir Act-designated Class I areas.

3 See reference#1, above.

4Ibid., See the Preamble to 40 CFR Part 51, Appendix Yfound in the Federal Register, Volume 70, No. 128, Wednesday, July 6, 2005, SectionIILE.6.d.

5Calculated bythe reviewer, noting the caveatthatthe combination oftons ofNOxand S02 may introduce an artifact. However, it may be accurate enough for examining the magnitude ofthe costnumbers.

6 See 40 CFR Part 51, Appendix Y. The U.S. Enviromuental Protection Agency finalized it's BART Guidelines on June 15,2005, andpublishedthepreamble and final ruletextinthe Federal Register on July 6, 2005. The rulemaking action added Appendix Y to Part 51, titled "Guidelines for BARTDeterminations Underthe Regional Haze Rule." See Section III.A. I.

7 Ibid., See the Preamble to 40 CFR Pilii 51, Appendix Y found in the Federal Register, Volume 70, No. 128, Wednesday, July 6, 2005, Section III.EA.

### Enclosure 2 

### Comments on Wyoming BART Determinations General Chemical Soda Ash Partners, Green River Works Boilers C&D September 15, 2008

At this facility two coal-fired boilers C and D are subject to BART. The boilers are currently controlled with electrostatic precipitators (ESP) for control ofparticulatematter, over-fire air for control ofNOx and no controls for S02. The costs ofcontrol alternatives were determined from estimates provided by equipment vendors Alstrom Power and Allied Environmental Solutions. The cost-effectiveness of BART control alternatives was seemingly judged against estimates provided by EPA in the BART Guidelines, 1 and in most cases controls were deemed as being too expensive and notbeing cost-effective. The BART Guidelines require that cost estimates be developedusing theEPA OAQPS Control CostManual2 Only inthis way can national, uniform comparisons bemade. TheBART Guidelines state, "The basis for equipment costestimates also shouldbe documented, either with data supplied by an equipment vendor (i.e., budget estimates
or bids) or by a referenced source (such as the OAQPS Control Cost Manua!...). In order to maintain and improve consistency, cost estimates should be based on the OAQPS Control Cost Manual, where possible. The Control Cost Manual addresses most control technologies in sufficient detail for a BART analysis. The cost analysis should also take into account any sitespecific design or other conditions identified above that affect the cost of a particular BART technology option."] Although 

### it is understood that the subject boilers are not Electric Generating Units (EGUs) above 200 MW, the preamble to the BART Guidelines in discussing

### c~st ranges states, "

...the majority ofBART eligible units greater than 200 MW can meet tlle presumptive BART limit at a cost of$400 to $2000 perton ofS02 removed.

.. Dry FGD cost effectiveness data ranged from $393 to $2132 per ton S02 removed, with an average cost effectiveness of$792 per ton.,,4 The cost ranges for Dry Flue Gas Desulfurization (Dry FGD) ($2,200 for D and $3,200 for C) presented in General Chemical's BART analysis are not far above the these upper values, even after factoring in supplemental re-construction costs ($474k). Also, recalculating costs downward by reflecting Control Cost Manual guidance and possible upward adjustment in the EPA EGU cost ranges for less cost-efficient smallerboilerunits, may further make the costs more reasonable. This cost-effectiveness may be considered reasonable when compared to all other BART reviews performed by the Federal Land Managers (FLMs). 5 Two examples are:

• Tell11essee Eastrnan in Kingsport, TN has proposed to add S02 scrubbers at a cost of $3,000

- $4,000 per ton to reduce impacts on visibility at Great Smoky Monntains National Parle

• Georgia Pacific in Big Island, VAhas proposed to add S02 scrubbers at a cost of$4,000 perton to reduce impacts onvisibility atthe James RiverFace Wilderness Area. Pleasere-develop the costestimates as indicated above andresubmitthe analysis.

General Chemical included a $4.8 million cost for a new stack if SNCR or SCR is installed. While thatmay be valid for SCR due to space constraints, we carIDot determine why it would be necessary for installation of SNCR, which is contained within the boilers. Since this cost represents well over halfofthe total Capital Investment for SNCR, a thoroughjnstification is necessary. The Wyoming DEQ used the General Chemical cost figures to conclude that SNCRwas not economically feasible. It is suggested that General Chemical re-calculate the SNCR costs withoutthe stackreplacementcost.
General Chemical inflated its scrubber costs by underestimating the effectiveness ofthe S02 scrubbing options evaluated'(90% for Wet FGD and 80% for Dry FGD) and by overestimating the operating costs by using apart ofthe EPA OAQPS Control Cost Manual that does not apply to acid gas scrubbers. The analysis shouldbe re"calculated using correct scrubbing effectiveness assumptions and cost calculation procedures. The corresponding reduced costs should be reported.

Section 6 develops various combinations of NOx and S02 controls (Options 6 - II) for development ofthe least-cost envelope for visibility impairment. The procedure outlined in the BART Guidelines demonstrates control alternatives for a single pollutant being compared in order to determine the most cost-effective control for that given pollutant via the least-cost envelope. The BART Guidelines do notprovide forjudging the cost-effectiveness ofalternative controls by summing costs for the entire facility beforejudging cost-effectiveness. In tins way comparisons to national benchmarks can be made. Section 6 (Options 6 - 11) sums 1he costs of NOx 

### I S02 control combinations before developing visibility impairment cost-effectiveness ($/dv). Then, General Chemical and the Wyoming DEQ make judgments of non-costeffectiveness using some unstated benchmark, likely derived from national benchmarks (e.g., $10 millionto $15 millionperdeciview) thatwere developed onaper-pollutantbasis. Options I

- 5 (I - 3 for NOx and 4 - 5 for S02) are correctly done for single pollutants, butthen
are incorrectly compared to one another on a single least-costenvelope, causing the dismissal of both S02 alternatives as notbeing onthe least-costcurve. Dry FGD and WetFGD are shownto be $10.3 million and $14.1 million per deciview, respectively. Certainly, Dry FGD should be considered as being cost-effective on avisibility improvementbasis.

Since Options I - 5 used single control alternatives for a singlepollutant, somejudgments canbe made on visibility improvement cost-effectiveness. SNCR is shown to cost $14,6 millionldv (and an average of $2,350 per ton for Units C & D). This is on the high end ofreasonable visibility improvement cost-effectiveness numbers, but tllis value should be considered reasonable given that Great River Energy is proposing to add a dry scrubber/baghouse combination to reduce S02 at its Stanton Unit #1 in North Dakota with a cost-effectiveness of improving visibility atTheodore RooseveltNational Park of$14.8 million/dv.

General Chemical only modeled impacts at the closest Class I area (Bridger Wilderness Area) and the Wyoming DEQ only modeled impacts at the two closest Class I areas (Bridger and Fitzpatrick Wilderness Areas). The FLMs typically ask for modeling at all Class I areas within 300 km, which would include Grand Teton and Yellowstone National Parks. This analysis shouldbe included.

Both General Chemical and the Wyoming DEQ compare visibility improvement ofthe control alternatives to 0.5 deciviews in an effoli to marginalize the visibility improvement projected to result from those control alternatives, This is a misuse ofthe Division's own guideline value of 0.5 deciviews. This value is used only to confirm that a BART-eligible facility "contributes" to visibility impairment (defined as a visibility impact greaterthan 0.5 deciviews at a Class I area)so as to become subject to perform a BART determination.6 It is incorrect to dismiss a control strategy on the basis that the resulting improvementis notperceptible or significant. EPA states in the preamble to its BART Guidelines that, "Even though the visibility improvement from an individual source may not be perceptible, it should still be considered in setting BART because the contribution to haze may be significant relative to other source contributions in the Class I
areas. Thus, we disagree thatthe degree ofimpairment shouldbe contingentuponperceptibility. Failing to consider less-than-perceptible contributions to visibility impairment would ignore the CAA's intent to have BART requirements apply to sources that contribute to, as well as cause, such impairment." 7 Regional haze is a cumulative regional issue with numerous sources contributing to the overall level of haze and therefore controls on a single source cannot be expected to resolve the haze issue. Nevertheless, small increments ofvisibility improvement at cost-effective rates from multiple sources will result in cumulative visibility improvement. This misinterpretation led the Wyoming DEQ to propose only combustion controls as BART, even though SNCR seems to be apossible cost-effective alternative as discussed above. Regarding S02 the Wyoming DEQ did not require General Chemical to install controls, but required that they participate in the Western Backstop Sulfur Dioxide Trading Program. The Bridger Wilderness Area is not one ofthe 16 Colorado Plateau Class I Areas considered by the Grand Canyon Visibility Transport Commission to be lmder this trading program. Therefore, S02 controls ofthe Section 309 sources should be evaluated and documented as to the effects on the Section 308 areas.
Aftercertainre-developmentofthe BART cost analyses as discussed above is performed itlooks
as though SNCR might be reasonably considered as NO, BART and Dry FGD might be reasonably considered as BARTfor S02.

1 See 40 CFR Part 51, Appendix Y. The U.S. Enviromnental Protection Agency finalized its BART Guidelines onJlU1e 15, 2005, andpublishedthepreamble and final ruletextinthe Federal Register on July 6, 2005. The rulemaking action added Appendix Y to Part 51, titled "Guidelines for BARTDeterminations Underthe Regional HazeRule."

20AQPS Control Cost Manual, Fifth Edition, February 1996, EPA 453/B-96-001. While this citation refers to the latest version at the time this guidance was written, you should use the versionthat is current as ofwhen you conductyour impact analysis. This document is available atthe followingWeb site: http://www.epa.gov/ttn/catcldirl/cslch2.pdf.

3 Ibid, see Section IV.D.STEP 4.5.

4 Ibid., See the Preamble to 40 CFR Pati 51, Appendix Yfound in the Federal Register, Volume 70, No. 128, Wednesday, July 6,2005, Section III.E.6.b.

5 Throughout this enclosure, the term "Federal Land Managers" and acronym "FLMs" refer to the U. S. Fish and Wildlife Service and the National Park Service, the Depatiment ofthe Interior agencies taskedwithprotection ofClean AirAct-designated Class I areas.6 See 40 CFR Part 51, Appendix Y. The U.S. Environmental Protection Agency finalized it's BARTGuidelines onJune 15,2005, andpublishedthepreamble and final ruletextinthe Federal Register on July 6, 2005. The rulemaking action added Appendix Y to Part 51, titled "Guidelines for BARTDeterminations Underthe Regional Haze Rule." See Section IILA.l.

"I Ibid., See the Preamble to 40 CFR Part 51, Appendix Y found in the Federal Register, Volume 70,No. 128, Wednesday, July 6, 2005, SectionIILEA.