UNITEDSTATESEN~RONMENTALPROTECnONAGENCY

REGION 8 

1595 Wynkoop 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 Implementation Plan for Regional Haze for the State of Montana 

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 review we 

identified the following: 

(1) Inadvertent inclusion of Colstrip 3 and 4 in a portion of the proposed regulatory text; 

(2) An omitted footnote in the proposed BART detenninations for Hokim; 

(3) A need to schedule the public hearings earlier than 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 BART detenninations for Hokim and Ash Grove. 

We explained in the disclaimer that appears at the top of the proposed notice on the Region's Website 

that the posted proposed rule is not the official version of the rule; and therefore corrections may 

occur between 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 of this Internet version of the rule, it is not the official version of 

the rule for purposes of compliance. Please refer to the official version in a forthcoming FR 

publication, which will appear on the Goverrunent Printing Office's FDSys 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: Correcting error, pages 294-295, and replacing those 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. 

Correction 2: Correcting error, page 79, and replacing that page. 

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.) 

Correction 3: Changes to public hearing dates/times, pages 2 and 282, and replacing those 

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 

2 
other 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 

3 University rd - 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: Correcting typographical errors in the proposed BART determinations for 

Holcim and Ash Grove Cement, pages 76, 284, 285, and 296, and replacing those 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. 

***** 

3 
o	 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 NO x 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 

4 
requirement 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 

5 
process 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 of the proposed rule that you 

signed. They merely correct inadvertent errors and change the dates and times for the public hearings. 

With your approval, these corrections will be made to the version of the proposed rule to be published 

in the Federal Register and we will inselt the above noted replacement pages that are attached to this 

Memorandum. We recommend that you correct these inadvertent errors and other changes needed 

and approve these changes by signing and dating below. 

Enclosures 

d-rJl-/2­

Date 

*Pn"nted on Recycled Paper 

6 
40 CFR part 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.
 

Subpart BB - Montana
 

2. Section 52.1370 is amended by revising paragraph (c)(27)(i)(H) to read as follows:
 

§ 52.1370 Identification of Plan
 

* * * * * 

(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 Management Plan, 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 CFR part 51.308(d)(3)(v)(E). The Department considers the 

visibility impact of smoke 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 section applies to each owner and operator of the following coal fired electric 

generating units (EOUs) in the State of Montana: PPL Montana, LLC, Colstrip Power Plant, Units 1,2; 

294
 

and PPL Montana, LLC, JE Corette Steam Electric Station. This section also applies to each owner and 

operator of cement 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 

of Blaine County # 1 Compressor Station. This section also applies to each owner and operator of CFAC 

and M2 Green Redevelopment LLC, 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 of this section: 

(l) Boiler operating day means a 24-hour period 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-hour period. 

(2) Continuous emission monitoring system or CEMS means the equipment required by this section to 

sample, analyze, measure, and provide, by means of readings recorded at least once every 15 minutes 

(using an automated data acquisition and handling system (DABS)), a permanent record of S02 or NO\ 

emissions, other pollutant emissions, diluent, or stack gas volumetric flow rate. 

(3) Kiln operating day means a 24-hour period between 12 midnight and the following midnight during 

which the kiln operates. 

(4) NO~ means nitrogen oxides. 

(5) Owner/operator means any person who owns or who operates, controls, or supervises an EGU 

identified in paragraph (a) of this section. 

(6) PM means filterable total particulate matter. 

(7) S02 means sulfur dioxide. 

(8) Unit means any of the EGUs or cement kilns identified in paragraph (a) of this section. 

(c) Emissions limitations 

295
 

I 

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 20 I0, and 1164 tons for 20 I I. The alerage is 

1.1 12 tons). 

Step 4: Evaluate Impacts and Document Results 

Factor 1: Costs of compliance 

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 of the kiln. EPA has determined that the default 20-year 

amortization period is most appropriate to use as the remaining useful life of the facility. Without 

commitments for an early shut down, EPA carmot consider a shorter amortization period in our analysis. 

In order to calculate the armualized capital cost, we multiplied the capital cost by the CRF. 83 

We calculated the average cost effectiveness 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. 

Table 41. Summary 0 f NO x BART C api 't a IC t A os nalYSlS , for 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 of 0.0944 which
 

is based on a 7% interest rate and 20 year equipment life. The justification for using the CRF of 0.0944 can
 

be found in Office of Management and Budget, Circular A-4, Regulatory Analysis,
 

http://ww\\'. \\'hitehouse.golilomb/circu lars_a004_a-4/.
 

Table 42, Summary of NOx BART Annual 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 of Management and Budget, Circu lar
 

A-4, Regulatory Analysis, http://www.whitehouse.gov/omb/circuJars_a004_a-4/. 

79 

Public 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 

1 p.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 public hearings will provide interested parties the opportunity to present infolTI1ation 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 comments during the public hearing. When we 

publish our final action, we will provide written responses to all oral and written comments received on 

our proposal. 

At the public hearing, the hearing officer may limit the time available for each commenter to 

address the proposal to 5 minutes or less if the hearing officer determines it to be appropriate. We will 

not be providing equipment for commenters to show overhead slides or make computerized slide 

presentations. Any person may provide written or oral comments and data pertaining to our proposal at 

the public hearing. Verbatim transcripts, in English, of the hearing and written statements will be 

included in the rulemaking docket. 

ADDRESSES: Submit your comments, identified by Docket ID No. EPA-R08-0AR-20l1-0851, by 

one of the following methods: 

http://wwvv.regulations.gov. Follow the on-line instructions for submitting comments. 

E-mail: hinkle.vanessa@epa.gov 

2
 

Fish and Wildlife Service manages the Medicine Lake WA, Red Rocks Lake WA. and U.L. Bend WA. 

The National Park Service manages Glacier NP 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 

of a regional haze FIPs, summarized in section IV.H, above. 

Initially, MDEQ met the requirement of 40 CFR 51.308(i)( 1) by sending letters to the FLMs 

dated November 5, 1999. The letters included the title of the official to which the FLM of any 

mandatory Class I Federal area could submit any recommendations on the implementation of the 

regional haze rule including the identification of impairment of visibility in any mandatory Class I 

Federal area(s) and the identification of elements for inclusion in the visibility monitoring strategy 

required by 40 CFR 51.305 and the regional haze rule. 

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. 

Lastly, 40 CFR 51.308(i)(4) specifies the regional haze FIP must provide procedures for 

continuing consultation with the FLMs on the implementation of the visibility protection program 

required by 40 CFR 51.308, including development and review of implementation plan revisions and 5­

year progress reports, and on the implementation of other programs having the potential to contribute to 

impairment of visibility in mandatory Class I Federal areas. We commit to continue to coordinate and 

consult with the FLMs as required by 40 CFR 51.308(i)(4). We intend to consult the FLMs in the 

282
 
-

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

5S.0poll-40, where E = rate of emission in pounds per hour and P = process weight rate in tons per hour. 

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 

The PM contribution to the baseline visibility impact for Ash Grove is very small; therefore, any 

visibility improvement that could be achieved with improvements to the existing PM controls would be 

negligible. 

Taking into consideration the above factors we propose a BART emission limit based on use of 

the current control technology at Ash Grove and the emission limits described above for PMIPM 10 as 

BART. We find that the BART emission limit can be achieved through the operation of the existing 

ESP. Thus, as described in our BART Guidelines, a full five-factor analysis for PM/PM 10 is not needed 

for Ash Grove. 

As we have noted previously, under section 51.308(e)(l)(iv), "each source subject to BART [is] 

required to install and operate BART as expeditiously as practicable, but in no event later than 5 years 

after approval of the implementation plan revision." Since we propose a BART emission limit that 

represents current operations and no installation is necessary, we propose a compliance deadline of 30 

days from the date our final FIP becomes effective. 

II. Holcim
 

Background
 

76 

o	 A SO} BART determination and emission limit of 11.5 Ib/ton clinker that applies on a 

30-day rolling average, and a requirement that the owners/operators comply with this 

SO} BART limit witrun 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=4.1 Op067 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., '-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 v.ithin 30 

days of the effective date of our final rule. 

•	 For Colstrip Units 1 and 2: 

o	 NO", BART determinations and emission limits of 0.15 Ib/MMBtu that apply singly to 

each of these units on a 30-day rolling average, and a requirement that the 

owners/operators comply with these NOx BART limits within five (5) years of the 

effective date of our final rule. 

o	 S02 BART detelminations and emission limits of 0.08 lb/MMBtu that apply singly to 

each of these units on a 30-day rolling average, and a requirement that the 

owners/operators comply with these S02 BART limits within five (5) years of the 

effective date of our final rule. 

o	 PM BART determinations and emission limits of 0.10 Ib/MMBtu that apply singly to 

each of these units on a 30-day rolling average, and a requirement that the 

284 

owners/operators comply with these PM BART limits within 30 days of the effective 

date of our final rule. 

•	 For Hokim: 

o	 A NOx BART determination and emission limit of 5.5 lbs/ton clinker produced 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 of the effective date of our 

final rule. 

o	 A S02 BART determination and emission limit of 1.3 Ibs/ton clinker produced that 

applies on a 30-day rolling average, and a requirement that the owners/operators 

comply with this S02 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 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 Corette: 

o	 A NOx BART determination and emission limit of.40 Ib/MMBtu that applies on a 

30-day rolling average, and a requirement that the owners/operators comply with this 

NOx BART limit within 30 days of the effective date of our final rule. 

o	 A S02 BART determination and emission limit of 0.70 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 of the effective date of our final rule. 

285
 

(I) The owners/operators of EGUs subject to this section shall not emit or cause to be emitted PM, SO:, 

or NO x in excess of the following limitations, in pounds per million British thermal units (Ib/MMBtLl). 

averaged over a rolling 30-day period: 

Source Name PM Emission Limit S02 Emission Limit NO;,: Emission Limit I 

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

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 of cement kilns subject to this section shall not emit or cause to be emitted 

PM, S02 or NOx in excess of the following limitations, in pounds per ton of clinker produced, averaged 

over a rolling 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 if the process weight rate of 11.5 8.0 

the kiln is less than or equal to 

30 tOilS per hour, then the 

emission limit shall be I 

calculated using E=4.1 Op067 

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= 55.0poll40, where E = rate of emission 

in pounds per hour and 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 of LP, Blaine County # I Compressor Station shall not emit or cause to be 

emitted NOx in excess of 21.8 lbs/hr (30-day rolling average). 

(4) These emission limitations shall apply at all times, including startups, shutdowns, emergencies, and 

malfunctions. 

296