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OAR Box 1790 

Prepped by Keeia Richards 

Document Number: 

217) ll-F-6 

Docket Number: 

A-90-37 

Printed 10/31/2008 12:43:16 PM Sheet 217 of 250 
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NATIONAL PARK SERVICE AND DOS. FISH AMD WILDLIFE SERVICE PRIORITIES 

FOR NEtf SOURCE REVLKV PACKAGE — 

10/28/94 .ftBQOESTED REFINEMENTS AND OTHER INFORMATION 

-- OUTSETS*-5'-SPA will louk Into adding regulatory language similar to choc 

proposed by NPS .and USFUS on 10/21 (and ln previous communications) into Che NSR 

package that will go co OMB. 

— APPLICANTS' IMPACT ANALYSES: Civon FLM and permitting authority resource 

(staff and money) constraints, the Draft 1990 New Source Review Workshop Manual 

language on p. £12. research and monitoring supporting existing adverse impact 

condition*: at Class I areas, the FLMs' legal mandates, and other policy/legal 

consideration.*-., it ie essential chat the r.«gulatione make clear that the PSD 

permit applicant performs AQRVc impacts analysis for Class I area, ln 

consultation with the affected M M and permitting authorities. Following ia some 

suggo*ced compromise language to relieve concerns chae tho FLMs "draw a line" AC 

what analysis is needed: Proposed revision tu (n)(4): 

The plan shall provide that the application for any new or modified 

major stationary source shall include, where necessary, sufficient 

information for the jSfected Federal Land Manager and permitting 

Authority tp -4eterming, in accordance with cne requirements Under 

paragraphs^(p) of this section, whother emissions from the proposed 

Source nr modification would have in adverse impact on any afr 

quality related values (includirift visibility) of a Class I atea. 

(TTtreris information shall include, but not be limited to, mod*ling 

analyses at.ggescad by EPA's Modeling Guidelines, including long 

1range transport modeling analyses for proposed sources located mora 

[than "50 km from a Class I area. 

— FIX CONSULTATION FO& CHANCES EXCLUDED FROM PSD/NSR: NFS and USFUS appreciate 

EPA's agreement that FLMs be consulted vir.h by permitting authorities to 

determine impaccs Co AQRVs when a cource requests that an activity, such as a 

pollution prevention activity, be excluded from TSD/NSR. For FAT.« and other 

applicability evaluations, which have the effect of removing certain activities 

from PSD/NSR review, NPS and USFUS would accept EPA's desire not to require FLM 

consultation, so long as the look back period io reduced from the currently 

proposed 10 years to a recurring five year period, which could coincide with 

Title V permit renewals. See the attachment showing examples where a look back 

of 10 years would prevent the besc, most innovative control technologies from 

being employed. 

— TRACK INCREMENT: NFS and USFUS understand that the Existing Sources Workgroup 

Report is aurrencly being finalized to inolude the consensus reached by the group 

last July to enforce and strengthen requirements co track increment. Once that 

report is submitted CO £FA, NPS and USFUS request ChaC EPA reconsider its current 

position and inolude provisions in the NSR package co strengthen increment 

tracking requirement.*:. NPS and USFUS will be prepared co discuss specific 

language ac EPA's convenience. 

— SIP REVISIONS FOR "GENERIC" ADVERSE IMPACT DETERMINATION: NFS and US FWS asked 

that EPA eonsidor including such requirements (as described in 10/14 paper) in 

the NSR package. NPS and USFUS request further discussion with EPA. 
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In our September 1, 199-4, comments regarding the July 11, 19*34. draft 

revisions to the New Source Review Reform package, we indicated thac a fiveyear look back period, rather than the proposed tnr, year period, ic more 

appropriaia-ifor-tha* "Clean Unit Exemption." lu our recent conference call, 

you requested that We provide ey-niples to demonstrate hov control 

determinations could change substantially over a ten year peHi-ad. We have 

reviewed Che EPAOs Ranking Reports and recent and historical BACT 

•determinations in the RACT/BACT/LAER Clearinghouse for natural gas fired 

turbines and for ooal fired boilers. Our review Indicates that, for nature! 

gas fired turbines. BACT has progressed from the New Source Performance 

Standard requirement (as high as 130 ppm) to current level A of 4 ppm (SCR) or 

li to 42 ppm (dry low-NO, technology). This represents a substantial 

improvement in available control technology, and demonstrates how, when 

implemented properly, RACT reviews can be technology forcing. We are concerned 

that, if an inappropriate number of exemptions arc allowed, this development 

of now, improved technology will be greatly delayed. Data for coal fired 

boilers Indicate that NO, levels have decreased over the past ten years from 

.6 or .7 lb/MMBTU to current levels of .17 lb/MMBTU. S0_ levels have decreased 

from approximately 1.2 lbs/MMBTU (some higher and Some lover) tn current 

levels of ..12 or .13 lh/MMBTU. Note that even over the past five years, both 

N0X and 302 levels have been approximately halved. The Clearinghouse data 

clearly •demonstrate that control technology can improve significantly over a 

ten, and even a five year period. We therefore request che EPA reconsider the 

Clean Unit Exemption proposal. The look back period should be five years at 

most, or ideally, the examption should only apply co units which are using 

cechnolo-jy which represents current BACT/LAER levels.