March 29, 2012 

Memorandum to the South Dakota Regional Haze SIP File 

Docket ID # EPA-R08-OAR-2011-0870 

Subject: Excerpt from South Dakota August 18, 2011 Public Hearing Recording 

From: Gail Fallon 

 Environmental Protection Agency, Region 8 

The purpose of this memorandum is to provide clarification regarding the State of South 

Dakota’s consideration of certain National Park Service (NPS) comments submitted with an 

August 17, 2011 letter. The comments related to amendments proposed by South Dakota to the 

South Dakota Regional Haze State Implementation Plan. The State did not include written 

responses in the amended SIP for this set of additional NPS comments related to: 1) kiln #6 at 

GCC Dacotah cement plant for reasonable progress controls; and 2) concerns that a plant in 

Nebraska, Gerald Gentleman Station, had opted not to install best available retrofit technology 

sulfur dioxide controls. The South Dakota Department of Environment and Natural Resources 

website, http://denr.sd.gov/boards/2011/2011sche.aspx, provides information on the August 18, 

2011 Board of Minerals and Environment public hearing. An audio recording of the entire 

hearing is available on the website. We have transcribed an excerpt of the audio recording below 

where the State discussed its consideration of the NPS comments. This SIP amendment was 

subsequently submitted to EPA on September 19, 2011. 

Speakers at the hearing are identified by bolded text. 

Rick Boddicker - The National Park Service comments - the first one - they are referring to 

some modeling that was conducted for South Dakota by the Western Regional Area Partnership. 

That modeling included presumed SO2 controls for a power plant in Nebraska. They are stating 

there that Nebraska apparently is not requiring them to put those controls on, therefore, we may 

not get the reductions that we anticipated. The other comment is in reference to their kiln # 6 at 

GCC Dacotah, and I believe Kyrik will talk about that briefly. 

Kyrik Rombough - The National Park Service’s comment is actually in reference to their 

comment that they submitted on our PSD permit for GCC Dacotah. Quick history is GCC 

Dacotah upgraded # 6 kiln system in like 1999 or 1996. We conducted a PSD permit for that 

upgrade in 2003. And the Park Service, at that time, submitted comments that we should look at 

what is called SNCR, or selective non-catalytic reduction system, for NOx control, or nitrogen 

oxide control, and as we discussed in responding to comments during that permit proceedings we 

did consider SNCR. We did not consider it BACT, or best available control technology, during 

that permit review primarily because, you know, over simplify this some, is the control 

technology that was decided upon was staged combustion. Staged combustion requires an 

oxygen deficient zone meaning it reduces oxygen and SNCR in essence needs oxygen to operate. 
So their chemistry portion works in different mechanisms. One needs oxygen, the other one 

wants to reduce it to make it work properly. The other item with SNCR is it uses ammonia and 

urea to make the reactions. Ammonia and urea that doesn’t follow or doesn’t do the reaction 

they call ammonia slip so it exits the stack, which causes what they call detached moons, 

potential visibility issues, and increases particulate matter emissions and condenses. Particulate 

matter was a concern in that, and you see we took that into consideration. The third item we 

were also dealing with at that time the National Park Service referenced a permit in Missouri that 

required it. That permit required basically emission limits or a requirement as far as controls, 

higher than what we proposed and required at GCC Dacotah. And GCC Dacotah is actually 

operating at approximately 50% of our limit. So a limit that had actually been achieved by an 

SNCR is higher than what we required (unintelligible). So at that time we did consider it. We 

considered it was not best available control technology, and we still would consider it not 

basically part of needing (unintelligible) to do a four factor analysis since that was 7 years old, 8 

years old in that regard. 

Chairman - The... in their letter it just says, “we think you should think about this,” basically. 

Kyrik - Yes 

Chairman - But they are not giving any numerical reasoning of, ah, the affect or why they think 

or want something changed. 

Kyrik - No, all they reference is their comment in January 2003 which is basically submitted on 

a PSD permit application which we responded to at that time with that type of analysis. 

Chairman - Is there anything in the proposed rule change that would relate directly to this? 

Kyrik - Not directly. Based on EPA’s comments (unintelligible). How this all started is, they 

wanted us to look at SNCR for the two wet kilns at GCC Dacotah. Which is basically in our SIP 

submittal for EPA. Not part of the rule but part of the SIP submittal. We did look at SNCR for 

those two wet kilns and decided it was not cost effective (unintelligible). 

Chairman - O.k. Other questions? Rick? 

Rick – Basically, the reasons for the proposed changes to the regional haze program were the 

fact that EPA said they would not approve our State Implementation Plan without the changes. 

So we worked closely with Otter Tail and with EPA to come up with these changes. They are 

both agreeable to them and we are confident now that we have an approvable State 

Implementation Plan for EPA.