**Fish and Wildlife Service and National Park Service**  **Department of Interior Comments**  **State of Maine Draft Regional Haze Rule State Implementation Plan**  **July 23**  **, 2010** The Fish and Wildlife Service (FWS) and National Park Service (NPS) would like to thank the State of Maine for their efforts towards an effective and interactive consultation with the Federal Land Managers on their Regional Haze Implementation Plan (RH SIP). Furthermore, we appreciate the State’s efforts in addressing our comments on the pre liminary draft document that we received back in 2009. Through cooperative efforts, the draft RH SIP is one of the best examples of a comprehensive and well written draft of the MANE

- VU States. We would like to further commend the State for addressing most, if not all, of the “MANE

- VU Ask” (“Ask”) identified by the MANE

- VU Regional Planning Organization (RPO). On numerous occasions, the FWS and NPS have expressed concerns with the lack of “Ask” implementation language in many of MANE

- VU State RH SIPs. These omissions have led to less than ideal expectations on our part that controls will be realized overall in the MANE

- VU Region . The State of Maine not only appears to have addressed the “Ask” , but has done an exemplary

job of describing the State’s intent to meet Maine’s share of emission controls. **Overall Comment s**  As mentioned above, we have concern over the success of the MANE

- VU Region realizing the overall emission reductions expected by th e “Ask”. Although Maine is actively implementing controls of the “Ask”, many States are not. There is a good possibility that reasonable progress goals that States’ are setting based on full implementation of these “Ask” will not be achieved without honestly

discerning which emission reductions will take place and which ones will not. It is our recommendation that Maine consider providing discussion and additional plots of the reasonable progress goals without the “Ask” that are based on either “on the way (OTW)/on the books (OTB) ” or “better than on the way” scenarios. An additional presentation, taking more realistic emission reductions into consideration, would offer a better representation of the span of control being implemented in the region. Although, we recognize that it is not within Maine’s power to get other States to comply with the “Ask”, none the less, the State should access whether or not Penns ylvania, Ohio, Massachusetts, and New York will meet their share of the “Ask”, and communicate and incorporate these findings. This is important given that these States were identified as key contributors to Maine’s Class I areas. **Specific Comments Chapter 1,**  **Introduction** Section 1.8: The State identifies a suite of anal ys is methods to produce a weight of evidence approach to basic source apportionment . Although we commend the weight of evidence approach, the FWS and NPS does not consider MANE

- VU’s application of the CALPUFF model as within recommended modeling practices. As such, the use of non

- standard models or2

configurations, customarily require a performance evaluation that demonstrates beneficial use, which was not presented in Maine’s SIP. **Chapter 8, Emission Inventory**  We commend Maine for being the first MANE

- VU State to implement the low sulfur fuel strategy
. It would be helpful to the reader if an explanation could be given as to why SO 2 emissions for EGUs increase between the 2018 OTB/OTW inventory and the final modeling inventory

. We recommend that Maine add text to clarify which emission reductions assumed in the final modeling inventory

(Table 8

- 4) are being implemented. Added language would explain questions such as: i s the final modeling inventory for non

- EGUs point and area source SO 2 emissions accurate for Maine’s actual implemented controls, and are all the Best Available Retrofit (BART ) emissions included in these inventories? **Cha pter 10,**  **Best Available Retrofit Technology**  An overarching concern is that it is not clear from the Maine BART documents (posted 6/29/10) how it applied any

o f the five factors in the BART anal ys es in making its BART determinations. For example, MAINE does not appear to have given much weight to the visibility b enefits that could be realized from the control strategies evaluated. At least, it is not clear how Maine applied this factor in developing its BART conclusions. As we shall discuss later, there appears to be great inconsistency 1 among the methods used by Maine to assess and evaluate costs and benefits that would result from the various control strategies chosen b y Maine as representing BART. The individual company BART determinations were not found in the record. Please add an Appendix to the State Implementation Plan for Regional Haze and include these documents to aid third

-party reviewers to deal with the complete record. The core purpose of the BART program is to improve visibility in our Class I areas, and BART is not necessarily

the most cost
- effective solution. In stead, BART represents a broad consideration of technical, economic, energy, and environmental (including visibility improvem ent) factors. We believe that it is essential to consider both the degree of visibility improvement in a given Class I area as well as the cumulative benefits of improving visibility across all of the Class I areas affected. There are at least six Class I areas impacted by M aine’s BART sources. We believe that it is appropriate to consider both the degree of visibility improvement in a given Class I area as well as the cumulative effects of improving visibility across all of the Class Iareas affected. Th e same metric should not be used to evaluate the effects of reducing emissions from a BART source that impacts only

one Class I area as for a BART source that impacts multiple Class I areas. Also, evaluating impacts at one Class I area, while ignoring others that are similarly s ignificantly impaired should not be done. Emissions savings from a source are benefits that will be spread well beyond onl y the most
- impacted Class I area , and should be considered

. While Maine

1 For example, MEDEP calculates cost/ton for the Androscoggin paper mill but does not calculate cost/dv. However, for the Wyman power plant, MEDEP calculates cost/dv but does not calculate cost/ton.3

presented data describing improvements to visibility at a specific Class I area that would result from the various control scenarios it investigated, the State has not explained how it incorporated this information on impacts upon all Class Iareas into its BART decision. For example, Wyoming evaluated cumulative visibility improvement for both its BART and reasonable progress determinations

—following are excerpts from those Wyoming determinations (with emphasis added):

 Visibility impacts were addressed in a comprehensive visibility analysis covering all three visibility impairing pollutants and associated control options. The cumulative 3

-year averaged visibility improvement from the baseline **summed across**  **the three**  **Class I**  **areas** achieved with LNB with separated OFA, upgraded wet FGD, and FG C for enhanced ESP (Post

- Control Scenario A) was 1.070 Δdv from Unit 1, 0.199 Δdv from Unit 2, 1.068 Δdv from Unit 3, and 0.892 Δdv from Unit 4. 2
 Visibility impacts were addressed in a comprehensive visibility analysis covering all three visibility impairing pollutants and associated control options. The cumulative 3

-year averaged98 th percentile visibility improvement from the baseline **summed across**  **all four**  **Class I**  **areas** achieved with LNB with advanced OFA, dry FGD, and a new full

- scale fabric filter, Post

- Control Scenario A for each unit, was 3.558 Δdv from Unit 3 and 1.963 Δdv from Unit 4. 3
 Visibility impacts were addressed in a comprehensive visibility analysis covering three visibility impairing pollutants and the associated control options. The **cumulat ive**  **visibility improvement**  **as compared to the baseline across Wind Cave NP and Badlands NP** achieved with new LNB with OFA at the 30

- day limit of 0.23 lb/MMBtu (based on the 98 th percentile modeled results) was 0.14 Δdv from each of the three units. The exp ected visibility improvement over the course of a full annual period would be even greater due to the annual BART limit that is based on 0.19 lb/MMBtu. 4
 Visibility impacts were addressed in a comprehensive visibility analysis covering all three visibility impairing pollutants and associated control options. The cumulative 3

-year averaged 98 th percentile visibility improvement from the baseline **summed across**  **both Class**  **I areas**  achieved with LNB with advanced OFA, wet FGD, and existing ESP with FGC (Post

- Control Scenario A) was 1.716 Δdv from Unit 1 and 1.934 Δdv from Unit 2. 5
 Visibility impacts were addressed in a comprehensive visibility analysis covering all three visibility impairing pollutants and associated control options. The cumulative 3

-year average d 98 th percentile visibility improvement from the baseline **summed across**  **both Class**  **I areas**  achieved with LNB with advanced OFA, upgrading the existing dry FGD, and a new full

- scale fabric filter, Post

- Control Scenario A for Unit 1, was 0.996 Δdv. 6

2 DEPARTMENT OF ENVIRONMENTAL QUALITY AI R QUALITY DIVISION BART Application Analysis AP

- 6040 May 28, 2009 NAME OF FIRM: PacifiCorp NAME OF FACILITY: Jim Bridger Power Plant 3 DE PARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION BART Application Analysis AP

- 6041 May

28, 2009 NAME OF FIRM: PacifiCorp NAME OF FACILITY: Dave Johnston Plant 4 DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION BART Application Analysis AP

- 604 7 May

2 8, 2009 NAME OF FIRM: Basin Electric Power Cooperative NAME OF FACILITY: Laramie River Station 5 DEPARTMENT OF ENVIRONMENTAL QUALITY AI R QUALITY DIVISION BART Application Analysis AP

- 6042 May 28, 2009 NAME OF FIRM: PacifiCorp NAME OF FACILITY: Naughton Power Plant 6 DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION BART Application Analysis AP

- 6043 May 28, 2009 NAME OF FIRM: PacifiCorp NAME OF FACILITY: Wyodak Plant4

Oregon considered cumulative benefits for the Boardman Power Plant SCR addition for reasonable progress: **Table 22:**  **Visibility Modeling**  **Results (percent**  **im provem** **ent)** Total visibility im pacts (sum of 98th percentile for all Class I areas) The BART guidelines reco mmend analyzing visibility im provement for the highest impacted Class I area with the assum

ption that any im

provement in the wo rse impacted area would result in im provement in the lesser im pacted areas. **However, since**  **the Boardm**  **an Plant**  **significantly im** **pac ts**  **14 Class**  **I Areas**  **within 300**  **kilometers, the**  **Departm ent**  **tried to**  **include other**  **param eters**  **that would**  **assess the**  **significance of**  **the im** **provements for**  **all Class**  **I areas**  **im pacted.**  **Therefore, the**  **Departm ent**  **added the number of Class I areas with im** **pacts grea ter than 1.0 delta deciview, the total delta deciviews for**  **all Class**  **I areas**  **(98th percentile),**  **and the**  **average delta**  **deciview for**  **all Class**  **I areas**  **(98th percentile).**  As can be seen in Table 21, any one of the parameters is fairly representative of the other parameters perhaps with the exception of WFGD. Given these results, the Department does not believe that adding additional parameters, such as total deciview days, would result in any other conclusions and would probably just add confusion to the analy sis (e.g., mo re days of im pacts than are in a year). Using the results of the visibility mo deling, the cost effectiveness of the control technologies is recalculated by relating the costs to deciview improvement (**Mt. Hood and all Class I areas** ) as shown in the following 2 tables. 7 Maine has ignored the other Class I areas where a given BART source is also causing or contributing to visibility impairment. The dollar cost per increment of visibility improvement would be substantiall y lower if full consideration is given to all affected Class I areas that would benefit from emission reductions. While we recognize that EPA has provided no guidance on this issue of assessing visibility b enefits that would result in multiple Class I areas when emissions are reduc ed from a given BART source, we commend Wyoming and Oregon for their initiative in addressing the issue. We also recognize that there is no “perfect” method for addressing cumulative benefits, but we firml y believe that Maine must show how it considered th e cumulative impact of the BART sources the affected Class I areas. We have suggested an approach to Maine that is consistent with available information and with the approach used by Wyoming and Oregon, and again request that MEDEP show how it has considered the cumulative benefits of potential BART reductions. Based upon our reviews of BART analyses across the U.S., we believe that cost
-per- deciview ($/dv) of visibility

improvement is the most
- common and most
-useful parameter for assessing the cost
- effectiveness of strategies to improve visibility in Class I areas . Our compilation 8 of BART anal ys es across the U.S. reveals that the **average cost/dv proposed by either a state or a BART**  **source is**  **$1 3**  **- $**  **20 million**  , 9 with a maximum of almost $50 million/dv prop osed by Colorado at the Martin Drake power plant in Colorado Springs. Section 10.7.2: In the Best Available Retrofit Technology (BART) determination section for FPLEnergy

Wym an, LLC, three unlabeled tables identify visibility benefits based on 1 st and 8 th high values (page 110). Our understanding is that the quality and quantity

of meteorology

used during the BART determinations fall within the recommended modeling practices. Maine voluntarily

agreed to limit evaluations to 1 st high values in lieu of generating 3 ye ars of quality

7 DEQ BART Report for the Boardman Power Plant Updated December 19, 2008 8 See http://www. wrapair.org/forums/ssjf/bart.html 9 For example, PacifiCorp has stated in its BART analysis for its Bridger Unit #2 that “T he incremental cost effectiveness for Scenario 1 c om pared with the baseline for the Bridger WA, for example, is reasonable at $580,000 per day and $18.5 million per deciview.”5

meteorological input. Please communicate that the State did not use the 8 th high to base their BART conclusion. Comments on the BART determinations for individual facilities that are subject to BART follow. We are focusing our comments on the BART determination s for the Verso Androscoggin and FPLWym an facilities because they have larger impacts than the other BART sources. We are also providing comments on the other BART sources. **Verso Androscoggin Paper Mill** The Power Boiler #1 and #2, and the Waste Fuel Incinerator (WFI) units at Verso Androscoggin Paper Mill are BART eligible. Both SCR and SNCR are evaluated for each of these units as BART options for controlling NO x emissions. In each case, we have concerns with th e cost estimation methodologies used: annual reagent and catal ys t costs are significantly above what should be expected, capital recovery factor calculations use annual interest rates nearly double the standard of EPA’s OAQPS Air Pollution Cost Control Ma nual, and recovery periods onl y half as long, and there are unexplained differences between the company’s proposal and the Maine cost estimates. In summary, our data indicates that both SCR and SNCR should be considered as viable NO x BART conclusions for these units, and that lower sulfur residual oils should be more fully

evaluated as an SO 2 BART option for the Power Boilers. We also have several questions regarding the SO 2 BART conclusion for the WFI. Please see the detailed comments contained in Attachment 1 for specifics. **FPL Energy Wyman Station** Power Boilers #3 and #4 at the FPLEnergy Wym an Station are BART

- eligible units. The State’s SO 2 BART anal ysis appears to be the only B ART anal ys is conducted by Maine in which cost
- effectiveness was not evaluated in terms of annual cost/ton of pollutant removed. Instead, Maine appears to have relied solely u pon annual cost/deciviews (dv) of visibility improvement. While we encourage the use of the $/dv metric, it was not properl y calculated nor applied in this case. Using the data available in the BART anal ys es, we assessed the cost per ton of SO 2 reduced by the BART options, as well as corrected $/dv calculations. B ased upon the results, we believe that it is reasonable to conclude that 0.5%

- 0.3% sulfur f uels are BART for the FPL boilers. See the discussion in Attachment 2 to these comments for further details. **SAPPI SD Warren Paper**  **Mill** We are confused as to the BART status for Power Boiler #1 at the SAPPI SD Warren Paper Mill. While the company

-prepared BART analysis (September 2009) did not mention this unit, the January 21, 2010, Maine BART analysis does identify and anal yz e BART controls for Power Boiler #2. The final Maine BART anal ys is for the facility, posted on June 29, 2010, is again silent on this unit. Please explain the BART eligibility status for the SAPPI SD Warren Paper Mill Power Boiler #1, and include any appropriate BART determination in the final SIP. Supporting information for this comment is included in Attachment 3 to these comm ents. **Domtar Industries, Inc.**

**– Woodland Mill** 6

The State did a good job of reflecting the five

- factor BART protocol in the Departmental Findings of Fact and Order for Domtar Industries, Inc.

– Woodland Mill. Section II makes reference from the company B ART determination to a Dry Electrostatic Precipitator BART alternative estimated to cost $4,640 per ton of particulate matter removed. It also makes reference to the Selective Non

- Catal ytic Reduction (SNCR) BART alternative estimated by the company to cos t $7,360 per ton of NO x removed. If the detailed information correctly supports the values shown above, then it may be reasonable to conclude that the cost per ton of removal was excessive. Maine seemed to rel y solel y upon the MANE

- VU visibility data to evaluate in a general way

the visibility impact of a given unit on nearby Class I areas, but individual modeling of each BART alternative was not performed. In the case of the Woodland Mill it seemed that by concluding that an alternative was not cost

- eff ective on a cost per ton basis, Maine believes that the specific cost of visibility improvement was not necessary . Normally, the visibility cost step is performed, even if cost per ton is deemed to be excessive. Existing SO 2 controls on Power Boiler #9 and the Lime Kiln seemed to be considered ‘top controls’, so further cost anal ys is was not necessary

.

**Lincoln Paper** As we understand Maine proposes that Lincoln be allowed to burn 2% S fuel oil . Additionally, SO 2 emissions from the recovery bo iler shall be controlled to 141 ppmv (dry basis) @ 8% O 2 on a 24

- hour block average basis when firing onl y black liquor or when firing a combination of black liquor and oil. The recovery boiler fires #6

- fuel oil. Oil fired in the recovery boiler alone shall not exceed 0.7% sulfur b y weight or 2.0% sulfur b y weight when firing a combination of black liquor and oil. The recovery boiler is fired with fuel oil for startup purposes (in order to initiate Black Liquor Solids (BLS) firing) in addition to shutdowns and other events which require the addition of oil firing. Maine should explain why u se of lower sulfur (0.7% S) fuel (that is already used when the recovery f urnaces fires 100% #6 oil) would incur a capital cost that made use of that fuel all the time too expensive. The Lincoln Paper BART determination is deficient because it does not evaluate the use of 0.7% fuel oil at all times. **Dragon Cement** Based upon the 6/29/10 BART anal ys is, Maine has determined that for NO x, Dragon shall operate an SNCR (Selective Non

- Catal ytic Reduction) system to reduce NO x emissions from the calciner to achieve a 45% control efficiency . NO x emission s from the kiln system shall be limited to 350.0 lb/hr on a 90 day rolling average and 1533.0 tons/year on a 12 month rolling to tal basis. We concur. **Katahdin Paper**7

Maine is limiting emissions from Katahdin paper's only BART source to < 250 tpy to exempt it from BART

. We concur. **Red Shield Old Town Fuel & Fiber** Maine is limiting emissions from Red Shield's Old Town Fuel & Fiber's only BART sources to < 250 tons/year to exempt it from BART

. We concur. **Rumford Paper** Maine is limiting emissions from Rumford Paper to less than 250 tons per year so as to exempt it from BART. Please assure that Departmental Findings of Fact and Order or other federally enforceable documents are promulgated to define the emission limitations and place them in the official BART record. **Verso Bucksport paper mill** MEDEP is capping the Verso Bucksport paper mill out of BART, but did not po st the actual permit that does so. Please post the pertinent permit. **Chapter 11, Reasonable Progress**  **Goals** By setting reasonabl e progress goals based on the “Ask”, rather than the OTW/OTB inventory, the MANE

- VU States have made it more difficult to demonstrate that they have implemented the controls necessary

to meet the reasonable progress goals. It would be helpful for Maine to discuss whether or not the OTW/OTB controls were sufficient to meet the uniform rate of progress at the Maine Class I areas. Section 11.3, Additional Reasonable Controls: On page 133, the statement is made that MANE

VU States have up to 10 years to implement reasonable controls. We believe this to be incorrect statement
. Itis our understanding that the regional haze rule re quires the controls to be in progress (e.g., BART determination or rule requirement) when the RHSIP is submitted as final. Table 11

- 5 summarizes SO 2 emissions in 2002 and 2018 modeling inventory for 12 sources that were assumed to be required to install BART controls. A similar table which summarizes actual BART reductions for Maine sources would be extremely helpful.8

MANE

- VU indicated that emissions were backfilled in the final inventory calculations in order to fully meet the Clean Air Act Interstate Rule ( CAIR) cap. When this backfill method was applied to sources outside of MANE

- VU emission rates for some sources were overestimated, ignoring State rules and consent decrees. Please explain in more detail how Maine consulted with these non - MANE

- VU States and how the re sults from this consultation were reconciled in making these emission control decisions. **Chapter 12, Long Term Strategy**  Section 12.7.2: Please identify whether the State implements a smoke management plan. If so, identify whether the program is voluntary or mandatory

and whether the impacts to the Class I areas are considered during the process. Table 12

- 1 lists non

- CAIR BART facilities that were modeled. Please confirm the modeled emissions are consistent with the actual BART determinations. It should be stated earlier in the document that Maine wil l be fully meeting the “Ask” b y 2018. Providing a statement to this effect at the beginning of the document will address reader questions earlier in the review of RHSIP
. Section 12.12: The State has done a good job discussing its commitment to ensure that the New Source Review/ Prevention of Significant Deterioration (PSD) Program in the State will work towards the interests of their regional haze goal by including Section 12.12 . This section links reasonable progress for visibility to the Prevention of Significant Deterioration requirements.