March 29, 2012

Memorandum to the South Dakota Regional Haze SIP Fi le 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 clarif ication regarding the State of South Dakota’s consideration of certain National Park Ser vice (NPS) comments submitted with an August 17, 2011 letter. The comments related to am endments proposed by South Dakota to the South Dakota Regional Haze State Implementation Pla n. The State did not include written responses in the amended SIP for this set of additi onal NPS comments related to: 1) kiln #6 at GCC Dacotah cement plant for reasonable progress co ntrols; and 2) concerns that a plant in Nebraska, Gerald Gentleman Station, had opted not t o install best available retrofit technology sulfur dioxide controls. The South Dakota Departme nt 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 heari ng. An audio recording of the entire hearing is available on the website. We have trans cribed 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 te xt.

Rick Boddicker- The National Park Service comments - the first o ne - they are referring to some modeling that was conducted for South Dakota b y the Western Regional Area Partnership. That modeling included presumed SO 2 controls for a power plant in Nebraska. They are stating there that Nebraska apparently is not requiring the m to put those controls on, therefore, we may not get the reductions that we anticipated. The ot her comment is in reference to their kiln # 6 at GCC Dacotah, and I believe Kyrik will talk about th at briefly.
Kyrik Rombough - The National Park Service’s comment is actually in reference to their comment that they submitted on our PSD permit for G CC Dacotah. Quick history is GCC Dacotah upgraded # 6 kiln system in like 1999 or 19 96. We conducted a PSD permit for that upgrade in 2003. And the Park Service, at that tim e, submitted comments that we should look at what is called SNCR, or selective non-catalytic red uction 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, ove r simplify this some, is the control technology that was decided upon was staged combust ion. 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 mecha nisms. One needs oxygen, the other one

wants to reduce it to make it work properly. The o ther 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 particul ate matter emissions and condenses. Particulate matter was a concern in that, and you see we took t hat 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 emissi on limits or a requirement as far as controls, higher than what we proposed and required at GCC Da cotah. 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 techno logy, and we still would consider it not basically part of needing ( unintelligible ) to do a four factor analysis since that was 7 yea rs 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 t hat time with that type of analysis.

Chairman - Is there anything in the proposed rule change th at 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 o f the SIP submittal. We did look at SNCR for those two wet kilns and decided it was not cost eff ective ( 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 t o come up with these changes. They are both agreeable to them and we are confident now tha t we have an approvable State Implementation Plan for EPA.