**UNITEDSTATESEN~RONMENTALPROTECnONAGENCY** REGION 8 1595Wynkoop Street DENVER, CO 80202-1129 Phone 800-227-8917 http://wwv.J.epa.gov/region08



### MEMORANDUM SUBJECT: Inadvertent Errors and Corrections to the Proposed Rule Signed March 20, 2012, Proposed Federal ImplementationPlanfor Regional Hazefor the State ofMontana and Partially Approving Montana's SIP Revisions for the Visibility Plan, Submitted on February

### 17~12.

# n FROM: Carl Daly

# ~:;{**3/2b/~')l-** Director, Air Program 

## /1/
__ I 

### W. Robert Ward**'''':<:::-~** L(.. ,-, 

### Regional Counsel TO: James 

### B. Martin Regional Administrator You signed the proposed rule described above on March 20, 2012. During our subsequent reviewwe identified the following: (1) 

### Inadvertent inclusion ofColstrip 3 and 4 in a portion ofthe proposed regulatory text; (2) An

### omitted footnote in the proposed BARTdetenninationsfor Hokim; (3) A need to schedule the public hearings earlierthan planned to maximize the Agency's time to respond to comments before the August 14, 2012 final action deadline, and confonning change regarding notice to the FLMs; and (4) Typographical errors in the proposed BARTdetenninationsfor Hokim and Ash Grove. We explained in the disclaimerthat appears at the top ofthe proposed notice on the Region's Website that the posted proposed rule is not the official version ofthe rule; and therefore corrections may occurbetween signature and publication. The EPA Regional Administrator, James Martin, signed the following notice on 3/20/2012, 

### and EPA is submitting it for publication in the Federal Register (FR). While we have taken steps to ensure the accuracy ofthis Internet version ofthe rule, it is notthe official version of the rule for purposes ofcompliance. Please refer to the official version in a forthcoming FR publication, which will appear on the Goverrunent Printing Office'sFDSys website (http://fdsys.gpo.gov/fdsys/search/home.action) and on Regulations.gov (http://www.regu1ations.gov) in Docket No. EPA-R08-0AR-2011-0851. Once the official version ofthis document is published in the FR, this version will be removed from the Internet and replaced with a link to the official version.
1

### The following text, in redline/strikeout format, reflects the changes required. 

### Correction 1: Correctingerror, pages 294-295, and replacingthose pages.
40 CFR part 52 is proposed to be amended as follows: PART 52

- [AMENDED] 1. The authority citation for part 52 continues to read as follows: Authority: 42 U.S.C. 7401 et se . Subpart BB

- Montana 

## ***** §52.1396 Federal implementation plan for regional haze. (a) Applicability. This section applies to each owner and operator of the following coal fired electric generating units (EGUs) in the State of Montana: PPL Montana, LLC, Colstrip Power Plant, Units 1, 2, 3,**~;** and PPL Montana, LLC, JE Corette Steam Electric Station. 

### Correction2: Correctingerror,page79, and replacingthatpage. Table 40. Summary of NOx BART Analysis Control Technologies for Holcim Control Option Control Effectivenes s (%) Emissions Reduction (tpy) Remaining Emissions (tpy) LNB+SNCR 58 645 467 SNCR 50 556 556 MKF 30 334 778 LNB 15 167 945 No Controls (Baseline) 0 0 1,1128-1-1 1 Holcim 2012 Response. (Holclm llsts NOx**e~SSlons** at 998 tons for 2009, 1,175 tons for 2010, and 1,164 tons for 2011. The average is 1,112 tons.) 

### Correction3: Changes to public hearingdates/times, pages 2 and282, and replacingthose pages. Public Hearings. We will be holding two public hearings for this proposal. One hearing is scheduled to be held in Helena, Montana on Tuesday, May**1~,** 2012 from 2 p.m. until 5:30 p.m. and 6:30 p.m. until 9 p.m. at the Lewis & Clark Library, 120 S. Last Chance Gulch, Helena, Montana 59601, (406) 447-1690. The
2other hearing is scheduled to be held in Billings, Montana on Wednesday, May**~~,** 2012 from 1 p.m. until 5 p.m. and 6 p.m. until 8 p.m. at the Montana State 3rd University

- Downtown Campus, Meeting Room

- Broadway III A, 2804 Avenue North, Billings, Montana 59101, (406) 896-5860. The hours for the both public hearings will be from 1 p.m. until 5 p.m. and 6 p.m. until 8 p.m.

*****

Under 40 CFR 51.308(i) (2), we were obligated to provide the Forest Service, the Fish and Wildlife Service, and the National Park Service with an opportunity for consultation, in person and at least 60 days prior to holding a public hearing on the Regional Haze FIP. We sent a draft of our Regional Haze FIP to the Forest Service, the Fish and wildlife Service, and the National Park Service
on February 16, 2012 and March 5, 2012. We notified the FLMs of our public hearings (as initially scheduled) on March 14, 2012. 40 CFR 51.308(i) (3) requires that we provide in our Regional Haze FIP a description of how we addressed any comments provided by the FLMs. We revised our proposed Regional Haze FIP to incorporate comments received by the FLMs.



### Correction 4: Correctingtypographical errors in the proposed BART determinations for Holcim and Ash Grove Cement, pages 76, 284, 285, and 296, and replacingthose pages.

rate of the kiln is greater than 30 tons per hour, then the emission limit shall be calculated using E 

### = 55. Opo·11--+4-40, where E 

### = rate of emission in pounds per hour and P 

### = process weight rate in tons per hour.

***** 3o	 A 802 BART determination and emission limit of 11.5 lb/ton clinker that applies on a 30-day rolling average, and a requirement that the owners/operators comply with this 802 BART limit within 180 days of the effective date of our final rule.
o The following PM BART determination and emission limit: if the process weight rate of the kiln is less than or equal to 30 tons per hour, then the emission limit shall be calculated using E=4.10po.67 where E = rate of emission in pounds per hour and p process weight rate in tons per hour; however, if the process weight rate of the kiln is greater than 30 tons per hour, then the emission limit shall be calculated using E = 55.**OpO.l1~-40,** where E = rate of emission in pounds per hour and P process weight rate in tons per hour. This limit applies on a 30-day rolling average, and a requirement that the owners/operators comply with this PM BART limit within 30 days of the effective date of our final rule.


### *****

• For Holcim: o	 A NOx BART determination and emission limit of**~~** lbs/ton clinker produced that applies on a 30-day rolling average, and a requirement that the owners/operators comply with this NOx BART limit within five (5) years of the effective date of our final rule. o	 A 802 BART determination and emission limit of**~1.3** lbs/ton clinker produced that applies on a 30-day rolling average, and a 4requirement that the owners/operators comply with this 802 BART limit within 180 days of the effective date of our final rule. o	 A PM BART determination and emission limit of 0.77 lb/ton lb/ton clinker produced that applies on a 3D-day rolling average, and a requirement that the owners/operators comply with this PM BART limit within 30 days of the effective date of our final rule. 

## *****
(2) The owners/operators of cement kilns subject to this section shall not emit
or cause to be emitted PM, 802 or NOx in excess of the following limitations, in pounds per ton of clinker produced, averaged Source Name

Ash Grove Cement 

### PM Emission Limit (lb/ton clinker)

if the process weight rate of the kiln is less than or equal to 30 tons per hour, then the emission limit shall be calculated using E=4 .10po.67 where E = rate of emission in pounds per hour and p = process weight

rate in tons per hour; however, if the process weight rate of the kiln is greater than 30 tons

per hour, then the emission limit shall be calculated using

E = 55.0po.11 -40, where E = rate of emission in pounds

per hour and = p over a rolling 3D-day period: S02 Emission Limit (lb/ton clinker) 11.5 NOx Emission Limit (lb/ton clinker) 8.0

5process weight rate in tons per hour. 

### Holcim Inc. (US) 0.77 lb/ton 

### 1.3 5.5



### These above changes to the proposed notice do not impact the substance ofthe proposed rule that you signed. They merely correct inadvertent errors and change the dates and times for the public hearings. With yourapproval, these corrections will be made to the version oftheproposed rule to be published in the Federal Register and we will inseltthe above noted replacementpagesthat are attached to this Memorandum. We recommend that you correct these inadvertenterrors and otherchanges needed and approve these changes by signing and dating below.
Enclosures



# d-rJl-/2­ Date



# *

Pn"nted on Recycled Paper640 CFRpart 52 is proposed to be amended as follows: PART 52 - [AMENDED] I. The authority citation for part 52 continues to read as follows: Authority: 42 U.S.C. 7401 et seq. SubpartBB - Montana 2. Section 52.1370 is amended by revising paragraph (c)(27)(i)(H) to read as follows: 

### § 52.1370 Identification ofPlan 

## * * * * * (c) 

## * * * (27) 

## * * * (i) 

## * * * (H) Appendix 0-2, Montana Smoke Management Plan, effective April 15, 1988, is superseded by 

## S 52.1365. 3. Add § 52.1395, Smoke ManagementPlan, to read as follows: 

### § 52.1395 Smoke Management Plan The Department considers smoke management techniques for agriculture and forestry management burning purposes as set forth in 40 CFRpart 51.308(d)(3)(v)(E). The Department considers the visibility impactofsmoke when developing, issuing, or conditioning permits and when making dispersion forecast recommendations through the implementation ofTitle 17, Chapter 8, subchapter 6, ARM, Open Burning. 4. Add section 52.1395 to read as follows: §52.1396 Federal implementation plan for regional haze. (a) Applicability. This sectionapplies to each owner and operator ofthe following coal fired electric generating units (EOUs) in the State ofMontana: PPL Montana, LLC, Colstrip Power Plant, Units 1,2;
294and PPL Montana, LLC, JE Corette Steam Electric Station. This section also applies to each owner and operatorofcement kilns at the following cement production plants: Ash Grove Cement, Montana City Plant; and Holcim (US) Inc. Cement, Trident Plant. This section also applies to each owner or operator ofBlaine County # 1Compressor Station. This section also applies to each owner and operator ofCFAC and M2 Green RedevelopmentLLC, Missoula site. (b) Definitions. Terms not defined below shall have the meaning given them in the Clean Air Act or EPA's regulations implementing the Clean Air Act. For purposes ofthis section: 

### (l) Boiler operatingday meansa 24-hourperiod between 12 midnight and the following midnight during which any fuel is combusted at any time in the EGU. 

### It is not necessary for fuel to be combusted for the entire 24-hourperiod. (2) Continuousemission monitoring system or CEMS means the equipment required by this section to sample, analyze, measure, and provide, by means ofreadings recorded at least once every 15 minutes (using an automated data acquisition and handling system (DABS)), a permanent record ofS02 orNO\ emissions, otherpollutant emissions, diluent, or stack gas volumetric flow rate. (3) Kiln operating day means a 24-hourperiod between 12 midnight and the following midnight during which the kiln operates. (4)**NO~** means nitrogen oxides. (5) Owner/operatormeans any person who owns or who operates, controls, or supervises an EGU identified in paragraph (a) ofthis section. (6) PM means filterable total particulate matter. 

### (7) S02 means sulfurdioxide. 

### (8) Unit means any ofthe EGUs orcement kilns identified in paragraph (a) ofthis section. (c) Emissions limitations

295I MKF 30 334 778 LNB 15 167 945 No Controls (Baseline) 0 0 1,112 I

.. Holcim 2012 Response. (Holclm lists NOx emiSSions at 998 tons for 2009. 1.175 tons for 20I0, and 1164 tons for 20II. The alerage is 1.1 12 tons). Step 4: Evaluate Impacts and DocumentResults Factor 1: Costs ofcompliance LNB We relied on cost estimates supplied by Hokim for capital costs and annual costs,81 but with t\\O

, exceptions. We used a capital cost estimate of$4,385,307.82 Also in our analysis, we used a CRF

consistent with 20 years for the useful life ofthe kiln. EPA has determined that the default 20-year amortization period is most appropriate to use as the remaining useful life ofthe facility. Without commitments for an early shut down, EPA carmot considera shorteramortization period in ouranalysis. In orderto calculate the armualized capital cost, we multiplied the capital costby the CRF. 83 We calculated the average costeffectiveness from the total annual cost and a 15% reduction from the baseline actual emissions of 1,112 tpy. We summarize the cost information for LNB in Tables 41,42,and43. 

### fNOx

### BART C 't IC t A , for Table41. Summary 0 

### api a os nalYSlS LNB on Holcim Description Cost ($) Total Capital Investment 4,385,307' Capital Recovery 413,9722

- I Holclm Additional Response, June 2009 (revised by EPA to eliminate I.) multiplier for "retrofit installation'').

Capital Recovery was determined by multiplying the Total Capital Investment by the CRF of0.0944 which is based on a 7% interest rate and 20 year equipment life. Thejustification for using the CRFof0.0944 can be found in Office ofManagement and Budget, Circular A-4, Regulatory Analysis, http://ww\\'.\\'hitehouse.golilomb/circulars

_a004

_a-4/. 

### Table42, Summary ofNOx

### BARTAnnual Cost Analysis for LNB on Holcim I 

### Description I 

### Cost ($) I

81 Hokim Additional Response, June 2009. 81 Hokim applied a 1.5 multiplier to the direct installation costs, for "retrofit installation." We did not. 83 CRF is 0.0944 and is based on a 7% interest rate and 20 year equipment life. Office ofManagement and Budget, Circular

A-4, Regulatory Analysis, http://www.whitehouse.gov/omb/circuJars_a004_a-4/. 79Public Hearings. We will be holding two public hearings for this proposal. One hearing is scheduled 10 be held in Helena, Montana on Tuesday, May 1,2012 from 2 p.m. until 5:30 pm and 6:30 p.m. until 9 p.m. at the Lewis & Clark Library, 120 S. Last Chance Gulch, Helena, Montana 59601, (406) 447­ 1690. The other hearing is scheduled to be held in Billings, Montana on Wednesday, May 2, 2012 from 1p.m. until 5 p.m. and 6 p.m. until 8 p.m at the Montana State University

- Downtown Campus, Meeting Room

- Broadway III A, 2804 3rd Avenue North, Billings, Montana 59101, (406) 896-5860. The publichearings will provide interested parties the opportunity to presentinfolTI1ation and opinions to EPA concerning our proposal. Interested parties may also submit written comments, as discussed in the proposal. Written statements and supporting information submitted during the comment period will be considered with the same weight as any oral comments and supporting information presented at the public hearing. We will not respond to commentsduring the public hearing. When we publish ourfinal action, we will provide written responses to all oral and written comments received on
ourproposal. At the public hearing, the hearing officermay limitthe time available for each commenterto address the proposal to 5 minutes or less ifthe hearing officer determines it to be appropriate. We will not be providing equipment for commentersto show overhead slides ormake computerized slide presentations. Anyperson may provide written or oral comments and datapertainingto ourproposal at the public hearing. Verbatim transcripts, in English, ofthe hearing and written statements will be included in the rulemakingdocket. 

### ADDRESSES: Submityourcomments, identified by Docket ID No. EPA-R08-0AR-20l1-0851, by
one ofthe following methods: http://wwvv.regulations.gov. Followthe on-line instructions for submitting comments. E-mail: hinkle.vanessa@epa.gov

2Fish and Wildlife Service manages the Medicine Lake WA, Red Rocks Lake WA. and U.L. Bend WA. TheNational Park Service manages GlacierNP and Yellowstone NP. Although the FLMs are very active in participating in the RPOs, the Regional Haze Rule grants the FLMs a special role in the review ofa regional haze FIPs, summarized in section IV.H, above. Initially, MDEQ met the requirement of40 CFR 51.308(i)(1) by sending letters to the FLMs dated November 5, 1999. The letters included the title ofthe official to which the FLM ofany mandatory Class I Federal area could submit any recommendations on the implementationofthe regional haze rule including the identification ofimpairment ofvisibility in any mandatory Class I Federal area(s) and the identification ofelements for inclusion in the visibility monitoring strategy required by 40 CFR 51.305 and the regional hazerule. Under40 CFR 51.308(i)(2), we were obligated to provide the Forest Service, the Fish and Wildlife Service, and the National Park Service with an opportunity for consultation, inperson and at least 60 days prior to holding a public hearing on the Regional Haze FIP. We sent a draft ofour Regional Haze FIP to the Forest Service, the Fish and Wildlife Service, and the National Park Service
on February 16,2012 and March 5, 2012. We notified the FLMs ofourpublichearings (as initially scheduled) on March 14,2012. 40 CFR 51.308(i)(3) requires that weprovide in our Regional Haze FIP
a description ofhow we addressed any comments provided by the FLMs. We revised ourproposed Regional Haze FIP to incorporate comments received by the FLMs. Lastly, 40 CFR 51.308(i)(4) specifies the regional haze FIP mustprovideprocedures for continuing consultation with the FLMs on the implementation ofthe visibility protectionprogram required by 40 CFR 51.308, including developmentand review ofimplementation plan revisions and 5­ year progress reports, and on the implementation ofotherprograms having the potential to contribute to impairment ofvisibility in mandatory Class I Federal areas. We commit to continue to coordinate and consultwith the FLMs as required by 40 CFR 51.308(i)(4). We intend to consult the FLMs in the
282

# -rate ofthe kiln is greaterthan 30 tons per hour, then the emission limit shall be calculated using E == 5S.0poll-40, where E 

### =rate ofemission in pounds per hour and P

## =process weight rate in tons perhour. Based on our modeling described in section V.C.3.a. PM contribution to the baseline visibilitv

. 

## . impairment is low. Table 38 shows the maximum baseline visibility impact from PM and percentage contribution to that impact from coarse PM and fine PM. Table 38. Ash Grove Visibility Impact Contribution from PM Maximurn Baseline % Contribution % Contribution

Visibility Impact Coarse PM Fine PM (deciview) 4.446 0.84 4.77
ThePM contribution to the baseline visibility impact for Ash Grove is very small; therefore, any visibility improvement that could be achieved with improvements to the existingPM controls would be negligible. Taking into consideration the above factors we propose a BARTemission limit based on use of the currentcontrol technology at Ash Grove and the emission limits described above for PMIPM 10 as BART. We find that the BARTemission limit can be achieved through the operation ofthe existing ESP. Thus, as described in our BART Guidelines, a full five-factor analysis for PM/PM 10 is not needed for AshGrove. As we have noted previously, under section 

### 51.308(e)(l)(iv), "each source subject to BART [is] required to install and operate BARTas expeditiously as practicable, butin no event later than 

### 5 years after approval ofthe implementation plan revision." Since we propose a BARTemission limit that represents current operations and no installation is necessary, we propose a compliance deadline of30 days from the date ourfinal FIP becomeseffective.
II. Holcim Background

76o	 A SO} BARTdetermination and emission limit of 11.5 Ib/ton clinker that applies on a 30-day rolling average, and a requirement that the owners/operatorscomply with this SO} BART limit witrun 180 days ofthe effective date ofourfinal rule.
o The following PM BART determination and emission limit: ifthe process weight rate ofthe kiln is less than orequal to 30 tons per hour, then the emission limit shall 

### be calculated using E=4.1Op067where E = rate ofemission in pounds per hourand p = process weight rate in tons per hour; however, ifthe process weight rate ofthe kiln is greater than 30 tons per hour, then the emission limit shall be calculated using E 

## = 55.0po., '-40, where E = rate ofemission in pounds perhourand P = process weight rate in tons perhour. This limit applies on a 30-day rolling average, and a requirement that the owners/operators comply with this PM BART limit v.ithin 30 days ofthe effective date ofourfinal rule.
• For Colstrip Units 1and 

### 2:
o 

### NO", BARTdeterminations and emission limits of0.15 Ib/MMBtu that apply singly to each ofthese units on a 30-dayrolling average, and a requirement that the owners/operators comply with these

### NOx BART limits within five (5) years ofthe effective date ofourfinal rule.


### o 

### S02 BARTdetelminations and emission limits of0.08 lb/MMBtu that apply singly to each ofthese units on a 30-day rolling average, and a requirement thatthe owners/operators comply with these 

### S02 BART limits withinfive (5) years ofthe effective date ofourfinal rule.


### o PM BARTdeterminations and emission limits of0.10 Ib/MMBtu that apply singly to each ofthese units on a 30-day rolling average, and a requirement that the

284owners/operatorscomply with these PM BART limits within 30 days ofthe effective date ofour final rule.
• For Hokim: o	 A 

### NOxBART determination and emission limit of5.5 lbs/ton clinkerproduced that applies on a 30-day rolling average, and a requirement that the owners/operators comply with this NO\ BART limit within five (5) years ofthe effective date ofour final rule. o	 A 

### S02 BARTdetermination and emission limit of 1.3 Ibs/ton clinkerproduced that applies on a 30-day rolling average, and a requirementthat the owners/operators comply with this 

### S02 BART limitwithin 180 days ofthe effective date ofourfinal rule. o	 A PM BARTdetermination and emission limit of0.77 lb/ton lb/ton clinkerproduced thatapplies on a 30-day rolling average, and a requirement that the owners/operators comply with this PM BART limit within 30 days ofthe effective date ofour final rule.
• ForCorette: o	 A 

### NOxBARTdetermination and emission limit of.40 Ib/MMBtu that applies on a 30-day rolling average, and a requirement that the owners/operators comply withthis 

### NOx BART limit within 30 days ofthe effective date ofourfinal rule. o	 A 

### S02 BARTdetermination and emission limit of0.70 Ib/MMBtu that applies on a 30-day rolling average, and a requirement that the owners/operators comply with this 

### S02 BART limit within 30 days ofthe effective date ofour final rule.



### 285(I) 

### The owners/operators ofEGUs subject to this section shall not emit or cause to be emitted PM, SO:,
orNOx

### in excess ofthe following limitations, in pounds per million British thermal units (Ib/MMBtLl). averaged over arolling 30-day period: Source Name PM Emission Limit S02 Emission Limit NO;,: Emission Limit 

## I (lb/MMBtu) (Ib/MMBtu) (lb/MMBtu) I 

### Colstrip Unit I 

### 0.10 0.08 0.15

Colstrip Unit 2 

## ! 0.10 0.08 0.15 JE Corette Unit I 

### 0.10 0.70 0.40 (2) The owners/operators ofcement kilns subject to this section shall not emit or cause to be emitted PM, S02 orNOx 

### in excess ofthe following limitations, in pounds per ton ofclinkerproduced, averaged
over arolling 30-day period: 

## I Source Name PM Emission Limit (Ib/ton clinker) S02 Emission Limit (Ib/ton clinker) NOx

### Emission Limit (lb/ton clinker) Ash Grove Cement ifthe process weightrate of 11.5 8.0 the kiln is less than orequal to 30 tOilS perhour, then the

emission limit shall be 

# I calculated using E=4.1Op067 where E =rate ofemission in pounds perhourand p = process weight rate in tons per hour; however, ifthe process weight rate ofthe kiln is greaterthan 30 tons per hour, then the emission limit shall be calculated using E=55.0poll40, where E= 

### rate ofemission

in pounds per hourand P= 

### process weight rate in tons per 

## I hour. 

## i Hokim (US) Inc. 0.77 Ib/ton 

### 1.3 5.5 (3) The owners/operators ofLP, Blaine County #

### I Compressor Station shall not emit or cause to be emitted NOx

### in excess of21.8 lbs/hr (30-day rolling average). (4) These emission limitations shall apply at all times, including startups, shutdowns, emergencies, and malfunctions. 

### 296