I4J 002

egiO! 4

124 25 h Street

, gden UT 84401

Region 2

740 Simms Street

Golden, CO 80401

PHYSICAL RESOURCES

United States

Department of

Agriculture

USDA

W5F

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1

Forest I'

Service

2009

!

1>S80 tOCT 2 1

I ' , I

1

File Code:

Date:

i

David A. Finley, Air Quality' dministrator

Wyoming Department ofEn ironmental

Quality - Air Quality Divisio

122 W. 2Sth St., Herschler B i1ding

Cheyenne, WY 82002

'

I Dear Mr. Finley:

The Forest Service (FS) has mpleted its review ofthe yoming RJgion I Haze State

Implementation Plan (SIP). he FS concurs and support the reVieW~d dings ofthe US

Department of Interior, Natio al Park Service, and Fish d Wildlife ervi e.

This plan's intent is to demo strate how the State ofWy ming will ake r asonable progress

toward meeting the national oal ofpreventing any futur , and remedying nyexisting,

impairment of visibility in m datory Class I areas. !

, The regulations describing w at these plans should conta n are foundlat 40 CFR S1.300 through

309. AI; the Federal Land Mager (FLM) for the North bsaroka, ~ash ie, Teton,

Fit.zpatrick, Bridger, ~avage . un, Mo~t Zirkel, Ra~ah, la~ Tops, at d Ea les Nest Class I

Wildernesses, the FS IS verYfterested m the Wyommg eglortal Ha e Pia .

As you are aware, the region I haze regulations at 40 CF SIJ08(i) ~qUir consultation

between the FLMs and the St teo Specifically: !

The State must provide the Pederal Land Manager with an a ortunity for lnsult tion, in person

and at least 60 days prior ta holding any public hearing on a Implementatibn plm (or plan revision)

for regional haze required this subpart. This consultation ust include t+e opp rtunityfor the

affected Federal Land Man gel's to discuss their:

lt's Cool to Be Safe PrInted on Recycled Papet

(i) Assessment ofimpairme t ofvisibility In any mandatory lass I Federallarea; nd ,

(ii) Recommendations on th development ofthe reasonable rogress goal alnd on he development

and implementation ofstrat gies 10 address visibility impair ent. I

Detailed comments on the S materials and related Best vailable R,btrofi Technology (BART)

materials are included with t~i~ letter, specifically, 1) FS omments gn the Regional Haze SIP,

2) FS Comments on Non-E~~ BART Sources, 3) FS Co ments on J1iGU ART Sources, 4) US

EPA Comments on Reasona~e Progress (for reference). i

The FS compliments you on ~our hard work and dedicati n to Signifij,ant iJ provement in our

nation's air quality values and visibility. Cooperative ef£ rts such as ,hese nsure that, together,

we will continue to make pro resS toward the Clean Air ct's goal 0 natu al visibility

. I

I

i

i

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PHYSICAL RESOURCES 141 003

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conditions at our Class I wild mess areas and parks. We appreciate tJle op ortunity to continue

to work closely with your ag cy as you develop this SIP Ifyou hat. que tions or connnents,

please contact Jeff Sorkin of ~ur Rocky Mountain Regio ,at (303) 2 '15-57 9.

Sin el, .

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United States

Department of

A ricnlture

Forest

Service

Intermountain Region 324 2 "'Street

Ogde ,UT 84401

80{-6 5-5605

File Code: 2580

Date: Octo er 31, 2008

Mr. David A. Finley, Admi 'strator

Division ofAir Quality

Department ofEnvironment I Quality

122 W. 25th Street

Cheyenne, WY 82002

Dear Mr. Finley:

The Forest Service (FS) has eviewed the Department 0 .Environme tal Q ality's (DEQ) Best

Available Retro-Fit Technol gy (BART) determinations for the B T-eli ible emission units at

the FMC Granger AP-6044, MC Westvaco AP-6045, d General hem cal Green River

Works AP-6046 facilities. T e BART determination is critical co pon t ofthe EPA

Regional Haze program to i prove visibility in our nati nal PllIks wil erness areas, of

which Regional Further Pro ess and the Long Term Str tegy are als key components, As

such, the decisions made by e DEQ under the BART p ocess may Iso feet the other program

elements affecting our natio 's ability to improve visibil ty. With th's bro der perspective, the

FS offers the following co ents on the DEQ's BART etern'linatio s.

ART modeling

Wyoming have

mately, the

o a direct

ave higher ozone

Similarly, the spatial distribu 'on ofthe ozone monitorin sites used i. the

analysis is suspect. Recent st dies ofmonitoring locatio, s in southw ,ster

certainly raised awareness of he complexity of addressin this 1ssue. Unfi

Pinedale ozone monitoring si was not operating during his study p .od,

comparison is not possible. owever, the area near Sout Pass appe rs to

Dispersion Modeling - Ozo e Concentrations:

The FS is concerned that visi ility impacts may be under stimated in the r fmed modeling, as

caused by an under-represent tion ofthe ozone concentr tion. The 0 one ata used in the BART

modeling is not believed to b spatially or temporally r resentative fthe ozone concentration

of a plume/pufftraveling fro any ofthe BART-eligible emission so rces near Green River

toward the Fitzpatrick and B dger Wilderness areas. E .. issions of . poll tants originating near

Green River must pass throu h the atmosphere near the J nab and W msu ter oil and gas fields

as they travel toward the Bri ger and Fitzpatrick Wilde ess areas. e oz ne data used in the

modeling is from 2001 throu 2003. In 2001, there wer reported 2 ',199 oil and gas producing

wells in Wyoming. By 2006, this number increased to a. proximatel 38,0 0 wells state wide!,

with associated increases in a r emissions. In 2006, the stoever win er ti e exceedance ofthe

ozone standard was experien ed in Sublette County. He ce, hOurly 0 one ata used in the

refined dispersion modeling. r the BART analyses is no temporally epre entative.

I Wyoming Oil & Gas Commission

Caring for the Land and Serv ng PeQple Printed on Recycled Paper 0:

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PHYSICAL RESOURCES

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concentrations than near Pin ale. As such, the FS is c cerned thaJ the zone data used in the

BART modeling is not spati lly representative. I

I

The underestimation of ozo concentration affects the Odel-predilted h e impacts primarily

for nitrates, as follows. Ozo e is the primary source of ydroxyl rad cals OR), which playa key

role in the formation of onium sulfate [(NH4)2S04] d ammonum n trate (NH4N03) in the

CALPUFF model. Ozone s es as the primary source· fhydroxyl adic s, which react with

NOzto form nitric acid. Th nitric acid reacts with am onia to fornj onium nitrate.

i

Figure I below illustrates thd effect of ozone concentrati n on the fo Imati n ofnitric acid

(RN03), which is also affeC~d by PG stability class and 02 conce atio. Underestimating

the ozone concentration by 2 ppb (e.g., 40 ppb instead f60 ppb), my r ult in a 50 percent

underestimation in the conve 'sion rate ofN02to nitric a id, and effe tivel reduce the modelpredicted haze by half for a iven hour.

I

Figure 1. Effect of Ozone ~oncentration on Nitric A id

10/21/2009 15:07 FAX 303 275 5122

Dear Mr. Finley

he more recent

d rerun the BART

-FGT=2

_.-FGT=3

FGT=4

0.05 0.09

one Concentration (p

.03

Q) 30.0

'Iii 25.0 0::

c:: 'C' 20.0

0 € 15.0 'i!! ;l.

...... 10.0· .-'': c::

0 5.0

0 0.0

0.01

I

To remedy this issue, the FS s requesting that Wyoming EQ re-evalluate

hourly ozone data to ensure appropriately representati e value is ured,

dispersion modeling analysis. I

t

Con rsion Rate of NOx 0 HN03

[NOx] =0.025 pp

Natural Background Conce tration:

The DEQ states that "Species concentrations correspondi g to the 20 erce t best days were

calculated for each Class I ar a by scaling back the annu I average co cent ations given in Table

2-1 ofthe EPA document Gu ancefor Estimating Natur I Visibility ond'tions Under the

Regional Haze Rule." Additi nal information is needed t understan and valuate the use of

scaling factors as applied to t e annual average concentra ions for cal.ulati g background

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Dear Mr. Finley

PHYSICAL RESOURCES 141006

3

concentrations for the 20 pe ent best days. As this info ati<lln is u 'ed i

change in light extinction, w 'ch is subsequently comp ed witIr thr shol

tIrorough understanding of is approach is needed for c ncurrence.

the quantification of

of acceptance, a

USDA Forest Service omments on BART D terrninat on r FMC Granger

The FS understands that two BART-eligible units were valuated an I dee ed exempt from

BART based upon refined d~ persion modeling. These t 0 units are1358. MMBtulhr coal-fired

boilers, each equipped Wi~GD scrubber and ESP cont oIs. ;

Given tire modeling concern expressed above, tire FS c ot concu with tire DEQ's

determination tIrat tIrese B T-eligible units are not su 'ect to BAR at t is time.

USDA Forest Service omments on BART D terminat on J r FMC Westvaco

Facility AP-6045

The FS has reviewed tire DE's proposed BART dete 'nation for t e thr e BART-eligible

emission units at FMC's We tvaco facility. We underst· d tIrat one fth e units, tire naturalgas fired boiler (PH-3), has b en determined not to be sli ~ect to B T ba ed upon tire results of

refined dispersion modeling. The remaining two units N -IAand N -lB, both coal-fired

boilers, are subject to BART. I

I .

In making its determination, e DEQ recognized and rei ed upon th fact at applying the

recently installed low NOx b rners and OFA for NOx is ufficient to brin the model-predicted

98th percentile impact below he 0.5 Adv threshold. As s ch, the DE rec mmends that no

additional controls are warr ted.

The FS acknowledges this ap roach, as many BART-eli ible source are sing federallyenforceable controls to reduc model-predicted impacts elow the su dect 0 BART thresholds.

However, recognizing that B T is one ofthree compo ents ofthe egio al Haze Rule tIrat the

State will use to achieve our ational visibility goals, we ncourage t Ie D to consider the

cumulative impacts ofsevera BART-eligible sources in e Green R vcr ea. Consider the

following discussion contain d in the preamble to the Re ional Haze ule p 39120-39121.

"In a regulatory context, we believe that a State's decisi n as to an a 'Pro riate thresholdfor

contribution could depend uppn the number ofsources a. ecting a cl s I a ea. To illustrate, if

there were only one emissio source affecting Visibility a class I a ea, t at source could have

a deciview impact only slight below the perceptibility t reshold wit out ontributing to

noticeable impairment. How ver, ifthere were IOOO sou ces each ch ngi visibility by 0.1

deciviews, the total impact w uld be a lO deciview chan in visibilitL. In this hypothetical

example, alii00 sources wou d be contributing in equal mounts to s~bsta tial visibility

impairment. " i

,

Currently, there are two BAR -eligible sources at the F C Grangcr iIit, three BARTeligible sources at the FMC estvaco facility, and two B RT-eligibl' sou ces located at

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Dear Mr. Finley

PHYSICAL RESOURCES

4

~007

i

General Chemical Green Ri er Works facility. Four of hese sevenJIOurc s have been

determined to be subject to ART, after refined modeli g.

The current approach propo 100 by the DEQ is to reduce missions om e ch subject to BART

source to controls, which re uce individual impacts fro each sourCJ' to j st below the 0.5 Mv

threshold.

Our general comments regar ing the dispersion modelin apply to t .s fac·lity. As such, the

model-predicted impacts rna be underestimated, which fthis is the :case, ould warrant further

emission reductions.

beyond the minimum prOPOSi'd by the DEQ are reasona Ie. Upon c nside ation ofthe

cumulative impacts from the e sources, additional contr Is impleme ted a this time will help the

DEQ move closer toward its easonable progress goals. enc~, whe er ese controls are

implemented as part ofBAR or under Reasonable Furt er Progress) such controls are viewed as

reasonable. I

S02 Controls:

The S02 controls identified fi I.' the two coal-fired boilers in DEQ's alysi are limited for two

options for increasing the am unt of gas routed exhaust tough the ret sc bber. However, the

EPA BART rule identifies se eral other wet scrubber up ade option, wh ch are not currently

addressed in the DEQ's anal is. These additional upgr e options' ,cIud installation ofliquid

distribution rings; installatio ofperforated trays; use of rganic acid addit ves; improve or

upgrade scrubber auxiliary s stem equipment; and redesi spray he del.' 0 nozzle configuration.

Each ofthese upgrade option should be considered in th BART an lyses

Analysis of Control Techno ogies in the Visibility Mo eling:

In evaluating the effectivenes ofthe various control opti us in reduc lUg h ze, it would be

helpful ifthe modeling result were presented for the co bination of LNB OFNSNCR (NOx)

and scrubber upgrades, both ithout and with a new byp ss (S02).

I

BART Determination:

TheDEQ determined that the installation oflow NOx bu OFA meetingNOx

emission limits of0.35 Ib/M tu (3D-day roIling averag ),represen B T for each ofthe

coal-fired boilers. The DEQ tates that this determinatio is based 0 the I.' suIts ofthe visibility

analysis, which show that F C's proposed BART contr option res Its in an average reduction

of 0.3 Adv in the 98th percent suIt at Bridger Wildemes Area as co par to the baseline

condition for each unit, and a reduction of 0.2 Adv in thc 8th percent esul at Fitzpatrick

Wilderness Area compared to baseline conditions. The 8th percenti e val es for both units

NS-IA and NS-IB were belo 0.3 Adv increase from ba kground co ditio s for all 3 years of

meteorology.

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Dear Mr. Finley

PHYSICAL RESOURCES

5

I4i 008

USDA Forest Service

Chemical Green River

This determination is based pon considerations ofthe odel-~redic,ed c ange in deciviews

compared to baseline conditi ns. EPA states in the pre ble to its· T Guideline2 that "Even

though visibility improvem t from an individual sourc . may not be erc tible, it should still

be considered in setting B T because the contribution 0 ha2!e may be si ificant relative to

other source contributions in the Class I areas." Given t e proximityofth two boilers, the

combined effect ofrequiring more stringent controls, suh as LNB/ A ith SNCR, will likely

allow the State to reach its re sonable progress goals

mments on BART D terminatilon r General

orks AP-6046

Dispersion Modeling:

Please refer to our previous c mments on o.zone concen

determination ofbackground oncentrations.

The FS has reviewed the DE's proposed BART determ nation for •e tw BART-eligible

emission units at General Ch mical Green River Works. We unders 'and t e two units are

tangentially fired boilers usi in-line pulverizers to bur low sulfur 'ubbi minous coal, which

supply power and process s m to the mining and ore p cessing op ,ratio s. Boiler C has a

firing rate of 534 MMBtu/hr d Boiler D has a firing ra of 880 M Bt . Each boiler is

currently equipped with a ho side ESP to control particu ates, overfi 'e air d low excess air

used to reduce NOx, and no dd-on controls for S02. 0 r comment1 are resented below.

i

."'"Md+of ~ting ",w,f~ ,

Effectiveness of Control Te hnologies: NOx

In its preamble to its BART uidelines, BPA states, "Ma y control t cOOi ues...can perform at a

wide range of levels.. .It is i pOItant, however, that in aly:ting th tee ology, you take into

account the most stringent e .ssion control level that t e tecOOolo y is apable of achieving."

The DEQ identifies the effec iveness ofNOx controls as follows: 10 N x bwners (LNB) with

separated overfire air (SOF ) achieve 30 percent con I; SNCR hiev s 50 percent control,

and SCR achieves 80 percent controL Lower NOx emiss on rates are achi able.

Low NOx burners with adv ced over-fire air, tangential y-fired boil rs ar able to achieve NOx

etnission rates between 0.14 nd 0.39 Ibs/MMBtu (equiv lent to 20-7 per ent control)'. Similar

emission rates were found i the NETL coal plant da base. For xam Ie, the Ameren Rush

Island Facility in Missouri s able to achieve annual verage N x e .ssion rates of 0.089

Ibs/MMBtu, and 0.0941bs/M Btu for its two boilers. A eren's Ne rton, llinois, facility is able

to achieve an aimual average Ox emission rate of 0.13· Ibs/MMBt I. S CR alone can achieve

between 30-50 percent reduct ons in NOx4

• SCR can ac ieve up to 0 per ent reduction5

•

2 Federal Regi,terNoL 70 No. 128 edoe,day, July 6,2005. Page 39129

3 Aisiom TFS 2000R Low NOx nlrol Syslerm

4 U.s. EPA Air Pollution Control T elmology Fact Sheet: Selective ou-C<ltalytic ~educ ·on. EPA'452/F-03-031.

'U.S. EPA Air Pollution Control T cImology Fact Sheet: Selective atalytic Redu ion: PA-4521F-03-032.

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Dear Mr. Finley

PHYSICAL RESOURCES

6

Iill 009

The use oflower than best a bievable control effectiven ss results i low r model-predicted

reductions in haze, and ther fore potentially affects the etenrtinatio of ART.

Costs:

The costs for applying each fthese control technologie is higher t an tical cost ranges. For

example, ultra low NOx b ers with advanced over-fir· air, tangen ially- Ired boilers cost

between $300 and $1200 pe ton, whereas the costs are stimated at 133 per ton for Boiler C

and $1433 for BoilerD. I

Typical SNCR costs are $50 - $1500 per cost are estimated at ton6

, whereas he propose

$2712 per ton for Boiler C d $2025 per ton for Boiler .

!

Western Backstop Sulfur ioxide Trading Program: I

The DEQ has stated that "G eral Chemical will not be equired to 4eet e·ther proposed

emission limit under BART. Instead, General Chemical will be req Ired t participate in the

emissions trading program der Chapter 14 ofthe WA SR should he pr gram be triggered."

Under 40 CFR 51.309 (g)(2) ii), the requirement under 1.308(e) reI ted t BART for regional

haze is deemed to be satisfie for pollutants addressed b. the milest es a d backstop trading

program if, in establishing th emission reductions miles ones under ara aph 40 CFR 51.309

(d)(4), it is shown that greate reasonable progress will b achieved Jr the e additional Class I

areas (e.g., Fitzpatrick and B idger Wilderness Areas) th would be achi ed through the

application ofsource-specifi BART emission limitation under 51.3 8 (e (1), Additional

information supporting this monstration is required, 01 erwise the O2 e ission limits

established under BART wil be in effect. 1

We appreciate your consider tion ofthese comments. S ould you h ve q estions regarding

these cOnmJents please conta t Bud Rolofson, FAA Staf, at (303) 2 ,5-57 2.

Sincerely,

lsi Brent Larson (for)

HARV FORSGREN

Regional Forester

cc: Mike Dudley

Bud Rolofson

Jeff A Sorkin

Rick Graw

Scott A Copeland

Ann Acheson

6 Midwest RPO Interim White P per - EGUs, March 2006

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PHYSICAL RESOURCES I4J 010

UNITED S TES ENVIRONMENTAL PRO ECTI'oN AG NC

REGION 8

1595 Wynkoop Street

DENVER, CO 60202-112

Phone 600·227-6917

http://www.epa·90v/reglonO

Ref: 8P-AR AtI6 f 22009

David A. Finley, Administrato

Division of f-ir Quality

Department of Environmental uaIity

122 W. 25th St. .

Cheyenne, WY 82002

Dear Mr. Finley:

Re: Prelimi

Specific Fo

Progress in

ary Gomme ts 0 WRAP's Source-

-Fac~or An lyses for Reasonable

yOlIling

Sincerely, ,

Please fin<j enclosed EP ,s preliminary comments 0 the dWaft Su le

Information for Four-Factor A dlysesfor Selectecllndividu .1 FacUlties I Wy

May 6, 2009. In addition, .som of these preliminary comme' ts pet!ain t the ay 4, 2009, draft

Supplementary In/ormation/or Four Factor Analyses by w:. P States, a oug EPA has not·

completed a full review of this .'general" report. These repo s wete prep ed EC/R

IncorPorated for the Western R gional Air Partnership ( P) and the este Governors"

Association ('\VGA). We unde stand that you intend to use f ese reports sup lement the

State's Reasonable Progress an lysis for the Wyoming Regi nal Ha2e SI

Please note these comm nts are highly preliminary. iven \:he na re 0 EelR's fourfactor analyses . and our uncerta' ty regarding their future use we dld, not Item t to ·identify every

concern. Also, as you know, w will only reach a final concl sion Iregard ng th adequacy of

Wyoming's.Reasonable Progre s analysis and Regional Ha2· SIP when e act n Wyoming's

Regional Ha2e SIP revision thr ugh notice and comment rul making.

Thank you for your con iderations ofour concerns. I you ~ave a y qu tions, you may

contact me at (303) 312-6434, r your staffmay contact Am Plait ,at (30 ) 312 6449,

I

I

4/\:1'~ "" '- . ~Vjdeti h, Director I

Air Program

Enclosure

OCT-21-2009 16:13 303 275 5122 99% P.10
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PHYSICAL RESOURCES I4J 010

UNITED S TES ENVIRONMENTAL PRO ECTI'oN AG NC

REGION 8

1595 Wynkoop Street

DENVER, CO 80202-112

Phone 800-227·8917

htlp:llwww,epe,govlreglonO'

Ref: 8P-AR AUG 122009

David A, Finley, Administrato

Division of Air Quality

DepartIhent'of Environmental uality

122 W. 25th St. .

Cheyenne, WY 82002

Re: Prelim; ary Oomme ts 0 WRAP's SourceSpecific Fo -FaCjtor An lyses for Reasonable

Progress in' yoming

Dear Mr. Finley:

Please find enclosed EP 's preliminary comments 0 the dlraft Su 'PIe

Informationfor Four-Factor A alyseslor Selecteqlndivid I FacUities i Wy

Mal' 6, 2009. In addition,.som of these preliminary comme ts pertain t the ay 4, 2009, draft

Supplementary Information/or Four Faotor Analyses by w: P States, a oug EPA has not

completed a full review ofthis .'general" report. These repo were prep ed EC/R

Incorporated for the Western R gional Air Partnership ( P) anc! the. este Governors"

Association (WOA). We unde stand that you intend to use t ese reports sup lement the

State's Reasonable Progress an lysis for the Wyoming Regi nal Haze SI

Please note these comm nts are highly preliminary, . iven lne na re 0 EC/R's fourfactor analyses and our uncerta' ty regarding their future use we did not !tern t to ·identitY every

concern. Also, as you know, w will only reach a final concl sion jregard ng th adequacy of

Wyoming's.Reasonable Progre s analysis and Regional H SIP when e act n Wyoming's

Regional Haze SIP revision thr ugh notice and comment rul making.

Thank you for your con iderations ofour concerns, I you have y qu stlons, you may

contact me at (303) 312-6434, ryourstaffmaycontactAm Platt,at(30 )3126449. ! '.

Sincerely, .

~~ /"'.

Callie A. Videti h, Director

Air Program

FnnJn~l,rfO'
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PHYSICAL RESOURCES

ENCLOSU

I4J 011

EPA R""gion 8 relilntllary Commeats on e M:\y 6, 2 Il!l, raft

, Supptemen ary In!ormatlonjdr Four- ' ctor Amity s10'

Set cted Individual Facilities in Wyoming

• Region 8 is concerned at Wyoming's draft ana'lysi does,not co side any additional

S02 measures necess for demonstratingReasona 'Ie Prdgress ) fi r the additional

Class I areas. Specific Hy, on page 1-1 ofthe repo the ct>Iltrac r wh developed the

report (HCIR Incorpored) states, "By. request from ' e W~omin stat representative,

S02 has not beenanaIy ed as S02 emissio\lS haYe b en adcllresse 'tbro gh the back stop

trading program." Wy ming is one of,four states p i'Cipating in the R giorialHaze 309

program (the others inc ude Arizona, New!Mexico d Utllh). A of yarning's seven

Class I areas are offth Colorado Plateau, and arere erred:to inPA's egulations as

"additional class I area ." Seclion 51.309(g) does n texclude th 309 tates that have

Class I areas offthe Co orado Plateau from addressi g 802 unde Reas nable Progress.

Specifically, 40 CFR 5 J09(g) states the 'following: 51.309(g) A did nal Class I areas.

Each Transpart Regi n State implementing the p, ovisltms Of his etion as the basis

for demonstrating RI,' for mandatory Cla.s I Fed ral areas oer t an the 16 Class I

areas Rlust include th following provisions in its mplementa~ion la'n. Ifa

Transport Region State submits an implementation ,an which is appro ed by EPA as

meeting the requireine ts ofthis section, it will be d emed to co lply ith the

requirements for RP fo the period from approval of he plan to 2 18,

(I) A demonstr tion of expect~d Visibility c nditicins for he m st impaired and

least impaired ys at the additiomil mandatD Cl$s rFe eral eats) based on

emissions proje tions from the long-term str egies'in the impl entation plan,

This demonstra ion may be based on assess nts conduct d by the StatesandJor a

regional planni g body,

(2) Provisions stablishlng reasonable pro ress goals a od I plementing any

additional mea ures necessary to demons! lite reason'a iJle p ogress for the

additional maatory Federal Class r area • These pr visio s must comply

with the provis ons of 51.308(d)(1) throng (4).

(I) In d veloping LTSs pursuant to 51.3Q8(d)(3 ,the tate may bund

upon th strategies implemented u der paragr ph ( 1 ofthis section,

and tak full credit for the visibili 'Improvement ac ieved through

these sl ategies.

I Paragraph d of this section includes requirements for the backstop trad ng pro~ram (B TP),

1

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PHYSICAL RESOURCES ~012

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The states' 309 SIPs must include provisions for stabli$hing r lason ble progress goals

and implement any dditional measures needed td demonstrate RP Ii r the Class I areas

offthe Colorado PIa eau. [5 1J09(g)(2)], The re ation~ provi e th t a state may take

creditfor and build pon the strategies impleinen~ d unq.er'the backs op trading program

(BSTP) in its RP an ysis. However, ,the state p:1U t provide a emo stration in its SIP of

howthe BSTP is me ting its visibility goals, and hy 802 con ols e not needed under

RP, Ifthe BSTP is ot meeting visibiiity goals, t en S02 con Is m st be evaluated

under RP.

• We have some over ching comments/questions r lated 'to this epo as well as the

May 4, 2009, draft S IfJplementary Injormationlo' Four Facto 'Anal ses by WRAP States

("General Repor!"). How did Wyoming select th sourdes to anal zed? How'were

,certain emission uni s selected? What sources an' source cate ories ere found to

significantlyimpact isibility? You wili need to 'scussiyour s leeti n criteria in the

Reasol1able Progress section ofthe SIP and explai whithe so ces ou select are the

appropriate sOurces address under Reasonable ,rogresslLon -te Strategy

requirements. Ifthe tate does not address certa! . sour~es or s mce ategories, or elects

to defer some reduct ons to a future planning peri d, the State ust ovide adequate

justification and doc entation for doing so" in ditioljt, with ut Ia wing Wyoming's

uniform rateofprog ess levels and how the ECIR eport~ will e use in Wyoming's SIP

effort, it is difficult fully review the informatio, presented. e wi 1need to review

how the information om these reports is used in our SIP to d term ne adequacy.

• Wyoming included t e two coal-fired boilers (Uni s BW41 & W42 at the Pacificorp

Dave Johnston e1ec c generating station, and the ounlain C ment ompany Laramie

Plant cement kiln in ts source specific,four-factor analysis reprt. H wever, it is

unknown how Wyo ing selected the sources that ere evaluat -d, he the significance of

the sources was dete ined (e.g., Q/d threshold), d what crit ria w re used to cut off

other sources or sour e categories from evaluation Wyqming ou! ensure that its SIP

includes a discussion ofthe methodology used to S lect sources and hy they are the

appropriate sources t~ address under Reasonable P ogress/Lon -term Strategy

requirements.

• Page 2-1, second par aph: The RACTIBACT/L R Clemo hOlls is another source

ofinformation for po enti&1 control teclrnologies 'at the State hou!d consult in

developing its SIP. Iso, we have conoemswith 'e second to ,asts tence of this

paragraph. Emission reduction requirements shou d be develop d thr ugh the four:factor

reasonable progress alysis, not before the analys s occurs.

• Section 2.3, first par raph,p.2-2: The first line s auld read," able 2-1 sunlmarizes the

energy and non-air q ality related environmental i pacts....."

• Table 2-1, p. 2-3: "*vironmental Impacts" shonl be "Non-A' Qua ity Related

Environmental Impa ts." Also, the first two ,itemslistecl',(wastegene ted and wastewater

generated) fall into, lcal categories ofimpacts e aluated unde non air qnality related ,

2

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I

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environmental impacts e.g., effects on the waste str am, virater c ns ption" andlor

waStewater disposal. 'owever, the remah:ling four es ofimpa ts lis cd do not fall into

these oategories oflin cts, and we recommend dele ing them ft ev 'uation,

• Pages 3-1 tlrrough 3-4 Tables 3-1 through 3-4): W oming shoul

IblMMBtu value for th Dave Johnston U1jlts, becau e con\<r?l e

,depend upon existing I IMMBtu emission rates.

• Page 3-2 (first paragra '): It is our unde$andillg til t cos~ Info

available for larger siz boilers so there should be' need to ex apm' te the capital cost,

data, In addition, the nual capital cost should be c lculated usi 19 a apital Recovery

F~ctor (CRF), which isladded to, not multiplied by, t e O&M co s. ' ,

• Page 3-2, last paragtap ,and Page 4-4, second para' aph: These timel nes for

compliance for the boil rs seem to be, overestimated: dloT don't co t for steps that

could be completed in arallel. SimiiarlY"an estinia' d seven y rs to ontrol the

'Mountain Cement Co any's Laramie Cement Plan kiln is not r "istl ,and should be

shortened, as a kiln is n where near as complex as a' ower plant. 'In a dition, the time,

necessary for complian e should not inciude time to, evelop re ation, If new

regulations are necess , such regulationS should be submitted 'th th forthcoming SIP,

The statement that two earsmay be need&! to devel p the' rnIes 1m 'lement the '

strategy implies that th State lacks authovity to deve op and sub it a S to address

Long-term Strategy an Reasonable Progress require ents, inclu'ling r levant reasonable

progress measures.

• 'Page 3-2 (Table 3-2): he estimated control efficien y ranges do ot a pear to be

reasonable, It would b er serve the reader to pravi e a best esti ate f control

efficiency as a distinct umber rather than' a tange ( ile a¢know dgin that there is a

range of uncertainty aro d that estimate in the text' r a foomote). For Ox, we suggest

using 40% for LNB, 60 for LNB with O'FA, 50% 'r SNCR, an 90· for SCR. It

should be,noted that N x controls can also be used i, comllinatio ,and the reductions

that result from using t e control technologies in co bination sh· ,Id ai' 0 be evaluated

and may low~r the over 1 $/ton numbers.

• Page 3-2 (Table 3-2): CIR has calculated,the emiss on realuctio num ers using the

upper end of the control efficiency range"which coul be mislead ng, gain, a central

estimate (with upper an lower bounds noted) should be provided with the tonna~e

reductions based on the est estimate.

• Page 3-2 (Table 3-2) an Page 3-3 (Table 3-3): EC has listed v 'ous control options

for use as individual co trol technologies. It should, e not¢d that hese controls can aiso

be used in combination, and the reductions that resul from !using e co trol technologies

in combination should so be evaluated; For examp e, you could instal LNB, OFA, '

SNCR, and SCR togeth r (in 'series), which might 10 er the over 1$/t n numbers,

3

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.. , . "."

that SCR r uces NOx emissions

owever, SC doe not co\,\vert NO, to

• Page 3-3, second p graph: In the first sentence,'Wyorning s uld dd SCR after

"SNCR," because b th control options use compr ssors andst to inject ammonia into

the flue gas. [n the s cond sentence in this paragr ph, t1w repo .stat s, "Installation of

SCR on an industria boiler is not expected to incr ase fuel con ump ion." However, this

may not necessanly e true, due to the fact that th· extent that . ower is used (i. e,

additional fancapaci to blow flue gas through t!< SCR, cataly t bed, and that when

power is replaced by increased boiler capacity, ad' itionail coal auld be burned. EPA

recommends modify ng the statement, or reinovin it altogethe:. In ddition, it should be

noted that catalysts e commonly regenerated riot only to save ost, ut also to eliminate

the waste stream ass ciated with catalyst disposal" which this r port hould acknowledge.

• Page4-1 (four:th par graph): Coke should be add 'to the list fuel that may be used in

cement kilns.

• Page 4,3, last two p ,agraphs: The report indiCl}te

from exhaust gases b converting NOxto nitrate.

nitrate; it.reduces N xto n\trogen gas (Nz).

• Page 4-5, first full se tence: The,report states, "r ere is'also t e add tional burden of

getting rid offouled r deactivated catalyst from e system - 0 en t e PM control device

in the form of a fabri filter or electrostatic precipi ator can ac ve t is goal." However,

in EPA's experience, one would not get rid of a c alyst with a 'M c ntrol device. As

noted above, catalyst are commonly regenerated t not only sa· e cos. but also to

eliminate a waste.st am, which this report should cknowledg .

• Page 4-5, section 4.4 The discussion on the rerna rung useful I fe in icates that the age

ofthe cement kilns . as not available to WRAP's ontractor. T 's i ormation should be

obtained and include in the SIP. '

• Page 4-6 (Table 4-2): 'The controlled amounts list d in tile tabl .for CR are incorrect;

they should be 262 t s/year. EPA believes that e SCR contr I effi iency should be in

the range of 80-90%, with corresponding cantrolle, amounts. or ex pIe, using SCR

with a 90% control e lciency would equate to 472 tons NO,/ye . In addition, in EPA's

opinion, the cost effi tiveness for low NO, burner (LNB) pres ,nted n this table seems

too high. We usually expect numbers between.$5 0 and $1,00 per t n for LNB.

4

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United State.

Department of

Agriculture

Fore.t

Service

Rocky

Mountain

Region

740 S mm. Street

Gold ,CO 80401

Voice 303-275-5350

TDD: 303-275-5367

File Code: 2580

Date: July. I, 2009

I

David A. Finley

Air Quality Administrator I

Wyoming Department of En· 'ronmental Quality

122 West 25th St.

Cheyenne, WY 82002

Dear Mr. Finley:

The Forest Service (FS)has mpleted its review ofthe est ayailabl retr fit technology

(BART) materials for the B T-subject electric generatng uriits (E 'Us), Jim Bridger and

Naughton power plants post on the Wyoming Dep ent ofEnvi onm tal Quality (WDEQ)

website. The FS concurs an supports the review and fi dingsiofthe U.S. epartment of

Interior, National Park Servi e, and Fish and Wildlife Se ice tegard g B T materials

submitted for the Dave John bn, Laramie River, and W'j dak EGUs.1

, -

These BART determinations are a key part ofthe region I haz¢ plan -he St te ofWyoming is

preparing. This plan will de onstrate how Wyoming wi I make reas nabl progress toward

meeting the national goal of reventing any future, and r medying a exi ting, impairment of

visibility in mandatory Class I areas. The regulations de cribirtg wh t thes plans should contain

are found at 40 CFR 51.300 tough 309. As the Federal Land Mana er LM) for the North

Absaroka, Washakie, Teton, itzpatrick, Bridger, Savag. Run, Moun t Zirk I, Rawah, Flat Tops,

and Eagles Nest Class I Wild messes, we are very intere ted in these BA determinations and

the Wyoming Regional Haze Plan as a whole.

The regional haze regulation at 40 CFR 51.308(i) requir con~ultati n be een the FLMs and

the State. Specifically, the F M is to receive 60 days to eview and mm t on any plan or

plan revision. The State mus also include a description f how it ad esse the FLM comments

ifthey are received in the spe ified timeframe.

As you know, the BART de ination must consider th - "best syste of ontinuous emissions

control technology" taking in account the following fac ors: "the te hnol gy available, the

costs ofcompliance, the ener and non air quality envir nmelital im acts ofcompliance, any

pollution control equipment i use at the source, the rem ininFf, usefu life the source, and the

degree ofimprovement in vis! ility," 40 CFR Section 51. 08(e)(I)(ii) A).

Our review ofthe five statuto y factors leads us to the co clusi¢m that sele ive catalytic

reduction (SCR) should be B T for nitrogen oxides (N x) fdr all u its a both the Jim Bridger

and Naughton power plants. e applaud the State ofW . ming for popos ng to install SCR at

the 4 units at the Jim Bridger GU. The FS believes the stalhltion t mefr e for SCR should

be within the 2015-2016 time ame for all four units at th facility.

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David A. Finley, WDEQ

PHYSICAL RESOURCES I4J 016

2

The FS believes that the alre dy-permitted installation 0 wet flue ga des furization (FGD)

equipment for the Jim Bridg Power Plant Units 1-4 sh. uld b~ B . S' Harly, the FS

believes that the installation fwet FGD equipment for t e Naughto Po r Plant Units 1-3

should be BART.

The United States Forest Se 'ce compliments you on y .ur hatd wor { and dedication to

significant improvement in 0 nation's air quality valu . and visibil ty. ooperative efforts

such as these ensure that, tog ther, we will continue to .ake pi-ogres i tow d the Clean Air Act's

goal of natural visibility con itions at our Class I wilder. ess areas a pars. We appreciate the

opportunity to continue to w rk closely with your agenc as ydlu dev lop nal BART

determinations for these faeil ties. If you have questions or commen s, pie se contact Jeff

Sorkin, at (303)-275-5759.

Sincerely,

lsiRick D. Cables

RICK D. CABLES

Regional Forester

Rocky Mountain Region

Enclosures

cc: JeffA Sorkin

Ann Acheson

Trent R Wickman

Terry Svalberg

Scott A Copeland

Bruce Polkowsky

Don Shepherd

Dean Gillam

OCT-21-2009 16:13

lsiHarv Forsgren

HARV FORSGREN

Regional Forester

Intermountain Region

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Unite States Forest Service Te

Wyoming BART de erminations for Jim Brid

The units under consideratio are four 530 MW units (n bered 1

power plant and 3 units at th~ Naughton power plant; 16 ,210,330

through 3. I

Overall Comments:

Power Plants

oug 4) at the Jim Bridger

W r spectively for units I

The FS connnends PacifiCo and the Wyoming DEQ f1 r the strong Ox ontrols proposed for

BART and reasonable progr ss. We believe the propos, controls ill si .ficantly improve air

quality in the many Class I eas surrounding the faciHti s. While w do ot agree with every

conclusion, the BART doc ents are thorough and well .tten.

Demonstration ofthe Exte t of Visibility Impacts:

,PacifiCorp modeled visibilit improvements from propo ed BART Id re sonable progress

controls. The FS feels it is i portant to document visibi,ity ill1pacts Cl s I areas as

completely as possible in ord r to place in context the to benefit d 'ved from controls. Then,

the cost of each BART altern tive should be divided by , e sum of ' dec view improvement at

all impacted Class I areas to etermine the cost per deciv ew. This aY re ult in acceptance of a

previously discarded control itemative due to the showi g of areas abl cost of visibility

improvement.

As such, the FS would like to see visibility benefit model'ng fqr all C ass I areas within 300km.

(see maps attached.) Additi ally, since there are Class areas just b yon 300km, if any

modeling already exists sho ing visibility improvement, enef'lts gre ter th 0.5dv beyond

300km, the FS requests that i formation be included as ell.

The State ofWyoming has d termined that the Savage R Wilderne sAra will be managed as

a Class I airshed. Therefore, he FS would like the Sava e Run Wild ,rnes Area to bc treated as

such in all Regional Haze pi ing including this BART cview.

Pages ES-5 and 5-10 ofthe P cifiCorp BART Aoalysis d scuss' "Just notic able difference in

atmospheric haze" indicating that minimal, if any, obse ble visibili y im rovements at the

Class I areas would be expec d under any ofthe control' enarios. I is in rrect to dismiss a

control strategy on the basis at the resulting improveme t is not per,epti Ie or significant. EPA

states in the preamble to its B T Guidelines:

"Even though the visi ility improvementfrom an dividual s rce ay not be

perceptible, it should ,till be considered in setting BARTbeca e th contribution to haze

may be significantrel tive to othersource contri tions in th Clas 1 areas. Thus, we

disagree that the deg e ofimpairment should be onti1lf5ent on rceptibility. Failing

to consider less-than- erceptible contributions to' isibility im airm 'lit would ignore the

CAA 's intent to have ARTrequirements apply to souroes tha cant ibute to, as well as

cause, such impairme t.,,3

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Five Factor Analysis for B RT Selection: !

In the BART detennination ihe State ofWyoming discu ses the app lcabirty ofpresumptive

BART to units at the Jim B ' ger and Naughton power .lants,: EPA vie ofpresumptive limits

for S02 and NOx for EGUs e that they are "highly cos effective," PA oes on to say:

"States, as a general alter, must require owner and operat rs 0 greater than 750 MW

power plants to meet hese BART emission limits, We are est blish 'ng these requirements

based on the conside ation ofcertain factors dis· ussed bela ,Alt ough we believe that

these requirements a e extremely likely to be app opriatefor II g ater than 750 MW I

powerplants subject a BART, a State may estab ish difJeren requ rements ifthe State

can demonstrate that an alternative determinatio isjustifle .base on a consideration of

the five statutoryfact rs:,4

So although the presumptive requirements are "extremel likely to b appr 'Priate" a State can

demonstrate otherwise based on the five statutory factor. The FS b ieve that the analysis of

coal composition is not only awed in its conclusions, re pI'incipa ly, it does not meet the

requirement for a demonstrat on ofwhy presumptive lim'ts cannot b reac ed.

NOx Controls:

The FS sees the infonnation resented as supporting SC. as B:ART r all units at both Jim

Bridger and Naughton power plants.

The State ofWyoming lists t e following reasons for not installing S R a BART on the 4 units

at the Jim Bridger power pi t and units I and 2 at the N ughtQn po er pI nt:

1) "The cost ofcompliance r installing SCR on each u it is signifl·antl higher than LNB with

separated OFA." !

2) "Combustion control usi g LNB with separated OF does not re uire non-air quality

environmental mitigation orthe use ofchemical rea· ents (i. e., a man 'a or urea) and there

is a minimal energy impa t."

However, the FS believes SC is BART for all units at b th facilitie , Th State ofWyoming

appears to concur with this fi ding because, in the deter 'ination, the tate says "The cost

effectiveness and incrementa cost effectiveness ofthefo r proposed 'AR technologiesfor NOx

are all reasonable". In addif n, FS is confused as to wbJ Wyoming eter ines SCR as BART

at unit 3 at the Naughton Po er Plant at $283Olton but fo unclear re ons ot at the other six

units with costs from $2258 - 2848/ton.

I

TheFS would like to point OIt that SCR is a mature tee ology. We e aware of any

enviromnental degradation d e to a properly operated SC . Furthe ore, ur inspection ofthe

cost analysis leads us to belie e the energy impact associ ted With op ,ratin SCR is included in

the cost analysis, which make this point raised by the St te moot.

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For the Jim Bridger Power ant units, the State ofWyo ing indica es:

"The cumulative 3-)1 ar averaged visibility impr, vementfro Pas -Control Scenario A

across the three Cia I areas achieved with Pas -Control Sc nari B was 0.627 .ddv per

unitfrom Units 1-3 adO. 635 .ddvfrom Unit 4."

This statement makes the ca e that SCR would result in' significant impr vement in visibility.

Each unit by itselfimproves isibility by an amount that resulis in" ntri ution" to visibility

impairment i.e. it exceeds O. dv. The total benefit ofS R on, the fo un ts (-2.5dv) easily

exceeds the threshold for "c sing" visibility impairmen , 1.0dv.

Similarly, for the Naughton ower Plant units, the State fWyomin indi ates:

"The cumulative 3-ye r averaged 98th percentile' isibility im rove entfrom PostControl Scenario A a ross both Class I areas ac ieved with ost- antral Scenario B was

0.405 .ddvfrom Unit, and 0.506 Mv from Unit, ."

Again, the FS sees this fact a making the case that this i a signific t im rovement in visibility.

Each unit by itselfimproves isibility by an amount that esults in, 0 'appr aches, a

"contribution" to visibility i pairment. The total impact f SCR on t e tw units approaches the

threshold for "causing" imp rment.

Regarding SCR in the BAR 7 of!the W omi g BART Application

Analysis shows a removal e lCiency of 84.4 percent for NB/OFN CR t reach 0.07

IbIMMBtu. PacifiCorp and yoming have underestima ed th¢ abili of odern NOx control

systems. SCR has been retro rtted to many eastern pulv ized coal b ilers that are now

achieving 0.05 IblMMBtu 0 a 30-day rolling average b sis. It is lik ly th t many ofthese

EOUs are burning eastern bit 'nous coals with higher' el-b(i)und n trog than that burned at

the Jim Bridger Power Plant. Because "jUel nitrogen ca accountfa .up t 80 percent oftotal

NOxfrom coal combustion" i should be easier for Pacifi, orp 10 achi ve I er NOx emissions

than an EOU burning coal w' higher fuel-bound nitrog n. IfSCR i cap ble ofreducing

emissions below PacifiCorp' target, then the amount of e reductio an consequent visibility

improvements will increase. These greater efficiencies s ould ,be fac ored .nto the cost and

visibility analyses.

Reasonable Progress Contr Is: I

The FS requests clarification s to why units I & 2 at the Naug/iton p~wer lant are not required

to install SCR as part ofreas nable progress like the oth, five 'units.

S02 ContrOlS:,

The FS believes that the alre y-permitted installation ofwet FOD e , ipm nt for the Jim

Bridger Power Plant Units 1- should be considered B 'T. Similarl , the FS believes that the

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installation ofwet FGD equi ment for the Naughton Po er PI~t U its 1- should be considered

BART.

There appears to be an error n the analysis for unit 3 at augllton. he p rformance ofthe wet

FGD was stated to be 0.10 1 MBtu (Table 18) but the cost effecti enes analysis was done

based on 0.15 lblMMBtu (T hie 24). The cost per ton Ii r S02 reduc ion s ould be calculated

using 0.10 lb/MMBtu, ifthatlis the correct value. '

The FS understands the role ifsection 309 in exempting; the state of yo ing from BART and

reasonable progress controlsfor S02 based on the demo, stration in Technical Support

Documentl

that the S02 emi$sions reductions benefits u der s@ction 09 e ceed those that would

have resulted from BART. t11lrther we understand that teState of yom ng has met it targets

under the 309 program. The IFS would like to know ifth controls' plac at the Naughton and

Jim Bridger Power Plants ar at least equivalent to the c ntrol ~cen 0 us d in the demonstration

report. In other words, are t existing S02 controls ac Ily as need d to ccomplish the "better

than BART" demonstration? ,

The FS also notes that the 30 program sunsets in 2018, d that add1tiona S02 controls may be

appropriate for reasonable p gress at that time. 1

Visibility Impairment: I

ys E.PA BART ~delin~s2 s ate that 0.5dv "cont.ri~utes' to iniP. airmln~, a d, 1.0dv "causes"·

Impairment. The diSCUSSIOn om Ronald Henry IS mele ant and use· 10 Improper context.

References: I

1. WRAP Technical Ov rsight Committee, Regiona Technical uppo t Documentfor the

Requirements of§309 ofthe Regional Haze Rule, 5/2008,

2. 40 CFR Part 51, App dixY. U.S. Environment I Protection Age cy, "Guidelines for

BART Determination Under the Regional Haze ule.", July ,20 5, See FR Vol 70, No

128, page 39161.

3. See 40 CFRPart 51, ppendix Y. The U.S. Env! onmental P otecton Agency finalized

it's BART Guidelines on June 15, 2005, and publ shed the pr bl and final rule text in

the Federal Register 0, July 6, 2005. The rulema ing action ded ppendix Y to Part

51, titled "Guidelines or BART Determinations ndertheR Haze Rule." See

Preamble,70FR30l2 ,middle column.

4. Federal Register, 7/61 5, p.3913l

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" N~DIslan""

I • Naughton PP

CIo...IUnb

! II,~ NPS I-I _FWSUSFS

, .,.- .'-.-

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..---- Jim Bli/lg$t DiStance

.,. Jim 81ldger PP

, ClossIIJIIIls

I!liJI NPS

• USFS 1. FWS

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