IN REPLY REFER TO:

I

United States Department of the Interior

FISH AND Wll.DLIFE SERVICE

National Wildlife Refuge System

Branch of Air Quality

7333 W. Jefferson Ave., Suite 375

Lakewood, CO 80235-2017

September IS, 2008

N36l5 (2350)

David Finley, Administrator

Air Quality Division

Wyoming Department of Environmental Quality

122 W. 25t11 St.

Herschler Bldg. 4 W

Cheyel1l1e, Wyoming 82002

Dear Mr. Finley:

The U. S. Fish and Wildlife Service (FWS) and the National 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 BART permit process is not a substitute for the Regional

Haze SIP adoption and review process, and we may have additional comments during the public

comment period. A 60-day consultation period on the RH SIP revision should be provided to !he

Federal Land Managers (FLMs) prior to a public hearing.

We are also in receipt of company-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 comment period after the DEQ analyses become available.

TAKE PRIDE"~

lNAMERICA~
2

We appreciate your efforts in managing 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,

Sandra V. Silva, Chief

FWS Branch ofAir Quality

Enclosures (2)

cc:

Callie Videtich

USEPA Region 8

1595 Wynkoop St., 8P-AR

Denver, Colorado 80202-1129

Rick Coleman

USFWS Region 6, Refuges

134 Union Blvd

Lakewood, Colorado 80228

Sincerely,

~l:tr:mcf /NPS Air Resources Division
Enclosure 1

Comments on Two Wyoming BART Determinations

FMC Wyoming Corporation, Westvaco Facility, Boilers #4, #6 and #7

September 15,2008

The BART determination was generally well developed. Boiler #4 is a gas-fired boiler that has a

NOx emission limit of 0.23 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, a wet alkaline scrubber for S02 and particulate matter (with a 50% flue gas bypass) and

an electrostatic precipitator (ESP) for particulate matter.

Analysis was provided for S02 control alternatives in Table 5-2 of the 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

compared to Option 2, Scrubber Upgrade & Stack Reheat ($3,513,039 Annual Cost, 5,827.6 tons

of S02 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 are projected. In such a case, low or reasonable cost effectiveness numbers

may validate the option as an appropriate BART alternative irrespective of the large capital

costs." I In this context, Option 2 (even though the annual cost is 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.

• Georgia Pacific in Big Island, VA, has proposed to add S02 scrubbers at a cost of $4,000

per ton to reduce impacts on visibility at the James River Face Wilderness Area.

In terms of cost-effectiveness relative to visibility improvement ($/dv), Option 2 also meets that

criterion at $8,344,510 per deciview. This value is 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 Dalmta with a cost-effectiveness of improving visibility at Theodore Roosevelt

National Park of $14.8 million/dv. Therefore, the FLMs propose that the most reasonable

assumption is the adoption of Option 2 as BART for 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 Section 308

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 of NOx 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 cost effectiveness of $673/ton. In presenting 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 structure presented in the

preamable might be generally less expensive on a cost per ton basis than would be expected for

smaller boilers. In terms of cost-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 that the most reasonable assumption is the adoption of Option 2 as BART for NOx•

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 of using single pollutant analysis comes from the universe of cost data

available for comparison purposes. FMC's BART determination in Table 7-6 developed

combinations of S02 and NOx control alternatives (Alternatives I - 4). As noted above there is

no provision in the 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

most reasonable assumption is the adoption of Alternative 4 as S02 and NOx BART (which is a

combination of the S02 and NOx choices noted in the above two paragraphs), especially if

visibility impacts on both the Bridger and Fitzpatrick Wilderness Areas are considered.

The next-to-last paragraph of Section 7.2 of FMC's BART determination compares visibility

improvement ofthe control alternatives to 0.5 deciviews in an effOli to marginalize the visibility

improvement projected to result from those control alternatives. The Wyoming DEQ embraces

this line of thinking in its proposed BART Determination. This is a misuse of the 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 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 of visibility improvement due to

installation of control equipment.

Specifically, the last paragraph of Section 7.2 of FMC'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 incorrect to dismiss a control strategy on the basis that the resulting improvement

is not perceptible 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 significant relative
to 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 of visibility 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 a cost-effective alternative as discussed above.

FMC states that three percent 01' less ofthe light extinction at the Bridger Wilderness Area is 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 of the FMC BART determination is not specific

in describing the "combustion air control" existing on this unit and the NOx control efficiency is

not stated. Cost-effective NO, combustion control alternatives can often be installed and they

should be analyzed in this BART determination.

I See 40 CFR Part 51, Appendix Y. The U.S. Environmental Protection Agency finalized its

BART Guidelines on June 15,2005, and published the preamble and final rule text in the 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 of Clean Air Act-designated Class I areas.

3 See reference #1, above.

4 Ibid., See the Preamble to 40 CFR Part 51, Appendix Y found in the Federal Register, Volume

70, No. 128, Wednesday, July 6, 2005, Section IILE.6.d.

5 Calculated by the reviewer, noting the caveat that the combination of tons ofNOx and S02 may

introduce an artifact. However, it may be accurate enough for examining the magnitude of the

cost numbers.

6 See 40 CFR Part 51, Appendix Y. The U.S. Enviromuental Protection Agency finalized it's

BART Guidelines on June 15,2005, and published the preamble and final rule text in the 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 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 of particulate matter, over-fire air for

control of NOx and no controls for S02. The costs of control 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 not being cost-effective. The BART Guidelines require that cost estimates be

developed using the EPA OAQPS Control Cost Manual 2 Only in this way can national, uniform

comparisons be made. The BART Guidelines state, "The basis for equipment cost estimates also

should be 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 of BART eligible units greater than 200 MW can meet tlle

presumptive BART limit at a cost of $400 to $2000 per ton of S02 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 smaller boiler units, 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, VA has proposed to add S02 scrubbers at a cost of $4,000

per ton to reduce impacts on visibility at the James River Face Wilderness Area.

Please re-develop the cost estimates as indicated above and resubmit the analysis.

General Chemical included a $4.8 million cost for a new stack if SNCR or SCR is installed.

While that may 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 half of the total Capital Investment for SNCR, a thorough jnstification is

necessary. The Wyoming DEQ used the General Chemical cost figures to conclude that SNCR
was not economically feasible. It is suggested that General Chemical re-calculate the SNCR

costs without the stack replacement cost.

General Chemical inflated its scrubber costs by underestimating the effectiveness of the S02

scrubbing options evaluated'(90% for Wet FGD and 80% for Dry FGD) and by overestimating

the operating costs by using a part ofthe EPA OAQPS Control Cost Manual that does not apply

to acid gas scrubbers. The analysis should be 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 of the 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 not provide for judging the cost-effectiveness of alternative

controls by summing costs for the entire facility before judging 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 million to $15 million per deciview) that were developed on a per-pollutant basis.

Options I - 5 (I - 3 for NOx and 4 - 5 for S02) are correctly done for single pollutants, but then

are incorrectly compared to one another on a single least-cost envelope, causing the dismissal of

both S02 alternatives as not being on the least-cost curve. Dry FGD and Wet FGD are shown to

be $10.3 million and $14.1 million per deciview, respectively. Certainly, Dry FGD should be

considered as being cost-effective on a visibility improvement basis.

Since Options I - 5 used single control alternatives for a single pollutant, some judgments can be

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 of reasonable

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 at Theodore Roosevelt National 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

should be included.

Both General Chemical and the Wyoming DEQ compare visibility improvement of the 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 of the 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 greater than 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 improvement is not perceptible 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 that the degree of impairment should be contingent upon perceptibility.

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 of visibility 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 a possible 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 of the 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.

After certain re-development ofthe BART cost analyses as discussed above is performed it looks

as though SNCR might be reasonably considered as NO, BART and Dry FGD might be

reasonably considered as BART for S02.

1 See 40 CFR Part 51, Appendix Y. The U.S. Enviromnental Protection Agency finalized its

BART Guidelines on JlU1e 15, 2005, and published the preamble and final rule text in the 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."

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

version that is current as of when you conduct your impact analysis. This document is available

at the following Web 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 Y found 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 of the Interior

agencies tasked with protection of Clean Air Act-designated Class I areas.
6 See 40 CFR Part 51, Appendix Y. The U.S. Environmental Protection Agency finalized it's

BART Guidelines on June 15,2005, and published the preamble and final rule text in the 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 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, Section IILEA.