U.S. Forest Service Draft Comments : Wyoming RH SIP

September 30, 2009

General comment : The Wyoming 309(g) RH SIP is a detailed document which addresses all of the

re quested elements outlined in the FS letter submitted to Wyoming DEQ, dated 8/2006. Neve rtheless, the FS has concerns regarding some technical approaches and policy considerations as outlined below.

General comment : The RH SIP does not appear to address visibility impacts at Savage Run Wilderness Area. Although this wilderness area is not one of the 156 Federal Class I areas, the State of Wyoming has determined that it should be managed as a Class I area. The State has officially declared Savage Run a Wyoming Class I area.

General comment : Multiple air quality modeling exercises (PRB Coa l Review, Pinedale Anticline, and others) identify potential ongoing visibility impacts in Class I areas within Wyoming and in adjacent States such as South Dakota and Colorado. How has Wyoming utilized the information available in these documents in the context of the 309(g) RH SIP ? How does Wyoming intend to utilize similar information in future iterations of the RH SIP process?

Chapters 4 and 5



### Tables 4.2

- 1 and 4.3

- 1 show projected decreases in overall state SO x 

### and NO x 

### emissions. However the same tables show i ncreases in SO x 

### emissions from Area s ources and NO x 

### emissions from Area s ources and Oil & Gas sources by 2018. The subsequent PSAT model results (Figures 5.2.1

- 1, etc.) show increases in SO x 

### impacts from Wyoming on the best an d worst 20% da ys at all three Wyoming Class I areas. The PSAT model also shows increases in NO x 

### impacts on the worst 20% days at YELL and BRID, and best 20% days at BRID. Because Wyoming is required to demonstrate that the State is obtaining “ its share of the emissi on reductions needed to

mee t the progress goal for the area ” , per 40 CFR 51.308 (d) 3, t h e FS believes that increasing Wyoming ’s imp acts at Class I areas cannot be understood to be reducing Wyoming’s “ share of the emission reductions. ”

40 CFR 51.308 (d) 3 ...In establishing its long

- term strategy for regional haze, the State must meet the following requirements:

...(ii) Where other States cause or contribute to impairment in a mandatory Class I Federal area, the State must demonstrate that it has include d in its implementation plan all measures necessary to obtain its share of the emission reductions needed to meet the progress goal for the area.

Figure 5.2.8

- 3. Where do all the EC emissions come from that cause 20% best days at BRID to have most EC fro m natural fire? In other words, h ow can “natural fire” be such a dominant fraction on these clean days? T he WEP analysis shows the overwhelming majority of EC on the cleanest 20% days at Bri dger are from “natural fire”; however, t he cleanest days at Brid ger principally occur in the winter when “natural fire” is rare compared to residential wood burning for example.



### Chapter 6
The FS acknowledges Wyoming ’s involvement in the SO 2 

### backstop trading program, and the corresponding regional SO 2 

### emissions red uctions. This program may well be contributing to noted decreases in sulfate concentrations in the mountain west.

FS is resubmitting its comments on Wyoming ’s non

- EGU BART facility since the FS original submittal was beyo nd the deadline for the initial n on

- EGU BART comment period. FS intends that the non

- EGU comments be considered at this time as official FS comments to the State of Wyoming regarding the SIP and associated BART strategies.

FS is resubmitting its comments on Wyoming ’s EGU BART determinat ions for completeness.

Chapter 7

The FS concurs with EPA Region 8 in its letter d ated 12 August, 2009, in that Wyoming ’ s 309 status does not absolve Wyoming of its requirement to perform reasonable progress analyses for SO 2 at Class I areas that are not part of the 16 Colorado Plateau Class I areas.

Has Wyoming demonstrated that its plan represents greater visibility improvement than is expected to result from implementation of other requirements of the CAA?

40 CFR 51.308 (d) 1 ...

(vi) The State may not adopt a reasonable progress goal that represents less visibility improvement than is expected to result from implementation of other requirements of the CAA during the applicable planning period.For example, Table 4.3

- 1 lists roughly 24,000 tons per year (TPY) of increase in NO x emissions from Area and Oil & Ga s sources, and roughly 7,000 TPY of NO x reductions from BART (Point) sources. The additional reductions of roughly 50,000 TPY come from mobile source rules which would be counted as

“ other requirements of the CAA ”. Not counti ng the mobile NO x reductions, Wyoming has chosen a reasonable progress goal that is a net addition of NO x , which represents “ less visibility improvement... ”

The use of a Q/d screening tool for evaluating reasonable p rogress controls seems reasonable for large stationary sources. Is Q/d based on unit emissions or facil ity/project emissions? Is it Wyoming ’s intent to decrease the Q/d threshold for future planning periods, hence allowing more facil ities to be considere d? Does Wyoming DEQ have a list of all considered sources (not just those over Q/d= 10) and the corresponding Q/d’s? If so, th at list should be included in the SIP. How many additional sources would be included if Wyoming applied a Q/d of 9 for example?

A Q/d analysis does not practically a ddress Area sources. How will A r ea sources be addressed under Reasonable Progress ?

From the 309 (g) Technical Support Document on the Wyoming DEQ website, this table lists sources with Q/d >10. P lease add to this t able the identification of which sources were controlled, by what technologies, and whether under BART or R easonable P rogress.

Section 7.3.5 When will the phase II report be available?Table 7.3.5

- 1 lists 16

- 36 $/ton for SNCR with 90

- 99% efficiency for compressor engines. Why not require this on all units?

Section 7.6

1. Neff, et al. 2008, suggest that roughly 75% of windblown dust is attributable to human activity. As such, it is not appropriate to use windblown as a reason for failure to achieve t he URP

.

6. While it is true that Western Class I areas are cleaner than their Eastern counterparts, that can make it less difficult to show improvement. That is, cleaner air is more sensitive to changes in pollution. This is why it is important to cons ider visibility impacts (e.g. $/dv) when determining control strategies.

Chapter 8

While tables 8.1.2.1

- 1 & 8.1.2.1

- 2 do an adequate job of demonstrating impacts from Wyoming emissions on surrounding States’ Class I areas, documentation of the projected i mpacts from Wyoming emissions on surrounding States’ Class I areas in the future is left in the 309 (g) Technical Support Document. All discussions belong in the SIP as part of the RP demonstration.

The comment that impacts from Wyoming emissions are “ a small portion of out

- of

- state visibility degradation” is subjective and perhaps misleading. For example, even if 18% of 14% is a “small portion”, that is on average over many days. The maximum d aily contributions could be much higher. In other words, impacts from Wyoming could be very large on an episodic basis. Further, proje ctions of future increases in Wyoming NO x impacts, (as shown below for best days at Mount Zirkel) could significantly increase Wyoming ’s share of impacts even as surrounding St ates try to meet their reasonable progress goals.P

. 130 : “By 2018, NO x emissions from Wyoming are projected by the WRAP to decrease by 39,861 tons, which will help reduce Wyoming’s impact to out of state Class I areas.” While these emissions should d ecrease impacts on average, localized emissions increases could clearly cause some Class I area impacts
to increase.

What is the final proposal for RP controls at Laramie Cement Plant ? What are the actual NO x emissions at Laramie Cement Plant? Are the y 524 TPY (Table 4.1 EC/R WY report) or 2080 TPY (Table 7

- 1 EC/R general report)?

The SIP proposes SCR f or NO x control at Laramie River and Jim Bridger power plants. The FS supports these decisions.

Section 8.3.4 Wyoming states that RP rulemaking wi ll be complete by 2013. It was noted ab ove that the FS believes that Wyoming has not demonstrated that it is meeting its share of emissions reductions fo r Class I areas inside and possibly outside of Wyoming . The WRAP commissioned reports 1,2 with supple mentary information for “four factor analyses” for a variety of source categories. Many of these analyses suggest low cost controls for source categories with significant emissions. The reports were delivered in May of 2009. Why is this information not mentioned or incorporated in the current SIP draft (other than as addendums in the TSD)?

Chapter 9

FS note s that Wyoming operates IMPROVE protocol samplers at Thunder Basin National Grasslands and Cloud Peak Wilderness. FS finds this information useful and wishes to a cknowledge Wyoming ’s efforts. The FS also acknowledge s the support we receive from Wyoming in providing a site operator at the North Absaroka IMPROVE site. Wyoming ’s cooperation in visibility monitoring is greatly appreciated.

Typo graphica l Corrections :

Section 5.2.9. Should “Fine PM” be “fine soil”?

Table 7.3.4

- 2 Column 3

- Potential Emission Reductions (1000 tons/ yr). Should be TPY

.P167 . “In spite of the large number of growing uncontrollable sources in the WRAP region, however,
W yoming does see a net visibility improvement at the Wyoming Class I areas through 2018.” Should read “uncontrollable sources impacting the WRAP region...”?

References :



### 1. Supplementary Information for Four Factor Analyses by WRAP States May 4, 2009, EC/R In corporated. 2. Supplementary Information for Four

- Factor Analyses for Selected Individual Facilities in Wyoming May 6, 2009, EC/R Incorporated.