;f. <.

USDA United States

Department of

Agriculture

Forest

Service

Rocl,y

Mountaiu

Region

740 Simms Street

Golden, CO 80401

Voice: 303-275·5350

TDD: 303-275-5367

File Code: 2580

Date: December 21, 2010

Steven A. Dietrich

Air Quality Administrator

Wyoming Dept. ofEnvironmental Quality

122 W. 25th St.

Herschler Building

Cheyenne, WY 82002

Dear Mr. Dietrich:

This letter documents the U.S. Forest Service's (FS) completion of a substantive review of your proposed

Regional Haze (RH) Rule State Implementation Plan (SIP) revision, specifically; the 309 and 309(g)

materials dated October 21, 2010. Please accept this letter and re-submittal of previous letters as FS

comments on Wyoming's RH SIP. Thank you for extending the Federal Land Manager (FLM) review

period through January 6, 20 II.

This plan's intent is to demonstrate how the State of Wyoming will make reasonable progress toward

meeting the national goal of preventing any future, and remedying any existing, impairment of visibility

in mandatory Class I areas.

The regulations describing what these plans should contain are found at 40 CFR 51.300 through 309. As

the FLM for the North Absaroka, Washakie, Teton, Fitzpatrick, Bridger, Savage Run, Mount Zirkel,

Rawah, Flat Tops, and Eagles Nest Class I Wildernesses, the FS is very interested in the Wyoming

Regional Haze Plan.

The FS previously submitted comments on Wyoming's RH SIP, RH SIP revisions, and related Best

Available Retrofit Technology (BART) determinations in writing October 19, 2006, October 31, 2008,

July 21, 2009, October 21,2009, and December, 3, 2010 (included as attachments). A more detailed

review ofthe recent SIP revision materials yielded no additional FS comments at this time.

The FS compliments you on your hard work and dedication to significant improvement in our nation's air

quality values and visibility. Cooperative efforts such as these ensure that, together, we will continue to

make progress toward the Clean Air Act's goal of natural visibility conditions at our Class I wilderness

areas and parks. We appreciate the opportunity to continue to work closely with your agency as you

develop this SIP. If you have questions or comments, please contact Randy Karstaedt, Director, Physical

Resources at (303) 275-5374, or by email atrkarstaedt@fs.fed.us.

Sincerely,

Is! Maribeth Gustafson

ANTOINE L. DIXON

Acting Regional Forester

Enclosures

It's Cool to Be Safe Printed on Recycled Paper -0
>DA

- United States

Department of

Agriculture

Forest

Service

Rocky

Mountain

Region

P.O. Box 25127

Lakewood, CO 80225-0127

Delivery: 740 Simms Street

Golden, CO 80401

Voice: 303-275-5350

TDD: 303-275-5367

Mr David A. Finley

Administrator

WYDEQ Air Quality Division

122 W. 25th St.

Herschler Bldg. 4 West

Cheyenne, WY 82002

File Code: 2580

Date: October 19,2006

Dear Mr. Finley:

Over the past several years, our staff has participated with members ofyour staff and those of neighboring states and

tribes in the Western Regional Air Partnership planning organization (WRAP), developing best approaches and tools

for preparing the plans that will reduce haze in Class I areas. Now that preparation of your Regional Haze State

Implementation Plan (SIP) is at hand, we want to work with you and your staffto help ensure that your SIP is

successful. As you know, our consultation with you is required in the Regional Haze Rule (RHR). This is my number

one priority for our air program.

Our focus will be on Class I wildernesses for which the USDA Forest Service is responsible. We also have a

coordination link with the other Class I area managers, the National Park Service and the US Fish & Wildlife Service,

to facilitate to the extent possible a common message from the federal land managers (FLMs). We should be able to

leverage the strengths from each ofthe FLMs. Since the FLMs will be seeking a close working relationship with every

state in this SIP-writing process, we expect to be able to share with you ideas from across the nation. As the manager

of eighty-eight Class I areas, we believe each state contributes to a national fabric of emission reduction planes). Such

planning is instrumental in attaining the natural background objective. Each and every SIP plays a critical role.

In the attachment, we have provided some detailed perspectives pertinent to SIP preparation. Any comments or

questions about these perspectives should be directed to Bud Rolofson, at (303-275-5752 brolofson@fsJed.us), your

principle Forest Service point of contact in this process. Bud will provide the required Forest Service consultation on

your SIP now, and through the required 60-day comment period. Working with others on our staff, especially our

National Haze Coordinator, Ann Mebane (307-587-4597, amebane(al,fsJed.us), and with the Department ofthe

Interior, he will provide you with our recommendations.

Please identify the key point(s) of contact on your staff with whom Bud may work on the SIP. Send all

correspondence to both Bud Rolofson and Ann Mebane. We would prefer this electronically to the extent possible.

I look forward to a fruitful consultation and a successful Regional Haze SIP.

Sincerely,

lsiSteve Sherwood (for)

RlCK D. CABLES

Regional Forester

Caring for the Land and Serving People Printed on Recycled Paper 0
cc: Mark Boche

Bud Rolofson

Jeff A Sorkin
Attachment

Subject: Regional Haze Rule Consultation with the USDA Forest Service, July 2006

The following perspectives are merely suggestions or recommendations not direction or

requirements. They are deliberately very similar to those prepared by the Department of

Interior to contribute to a common sense ofpurpose for improving haze in all Class I

areas. We are sending these perspectives to each state. In so doing, we hope to facilitate

inter-state coordination. At the same time, we fully acknowledge the discretion afforded

in the RHRfor unique and creative solutions by individual states in writing plans that

reduce haze.

Natural Condition, and Uniform Rate

These factors apply mainly to States that have Class I areas. Other States that contribute

to visibility impairment in Class I areas, located in a different state might consider

including discussion and conclusions on these factors in their individual plans.

The basic calculation of baseline, natural condition, and uniform rate builds the

foundation for the entire RHR SIP process. Considerable discussion and debate at the

science and policy level has occurred regarding appropriate methods to be used.

Consequently, several equations that include varying parameters or multipliers are

available. Because these calculations can have a significant effect on the resulting

progress goal, it is important to provide a detailed description ofthe methods used in the

SIP. Calculations that include only portions of established methods or utilize unique

approaches will be better understood ifthe rationale for these differences is fully

explained in the SIP or its supporting documentation. We encourage states to use

calculations that are based on equations recommended by the IMPROVE steering

committee and that are consistent with recommended approaches from the pertinent RPO

and the Environmental Protection Agency (EPA) region.

Emission Inventories

Given the complexities associated with modern comprehensive emission inventories,

spending some considerable effort in describing how these inventories were developed

and used will be important. Emission descriptions will be most informative ifthey

include an evolutionary discussion that includes; an actual, base-year inventory used to

evaluate model performance; a typical, base-year inventory that represents the five year,

average state which establishes modeled visibility impacts; and various future year,

controlled inventories that demonstrate future visibility conditions. Consider adding

future year inventories that are clearly partitioned to delineate source types (by text,

charts, or graphics) that are included in each model simulation. Benefits to future

visibility conditions suggested in the SIP that are not also clearly linked to a future

inventory or are not clearly included in future model analysis, will warrant additional

discussion.

One part of your emission inventory includes the implementation of "Best Available

Retrofit Technology" (BART) on a subset of pre-Prevention of Significant Deterioration

sources. BART source identification, elimination, and level determination will be of

particular interest for review. We would prefer to see a clear progression through the

three basic BART phases and a thorough description ofthe RHRprescribed factor
analysis (if applicable). Consider discussing whether BART levels apply to individual or

grouped source categories.

Area oflnfluence

The area ofinfluence ofsignificant visibility-impairing sourceS is an important SIP

element. We suggest that that each state clearly identify and apportion by State, or other

geographic means, the significant levels of pollutants contributed to each Class I area by

source. Developing this information together with neighboring States and Tribes will

facilitate consistency. Discussions of changing source area contributions at both the

base- and future-year levels will help demonstrate SIP progress. Consider the benefits of

presenting this information in the form oftransported mass by pollutant or through

individually calculated visibility impairment measures. Using a percentage or "Top 10"

ranking for current contributions by geographic area mayor may not clearly describe

progress over time.

Reasonable Progress Goals and Long Term Strategy

Establishing reasonable progress goals for Class I areas in your State and/or

aclmowledging reasonable progress goals for Class I areas in other States that are

affected by emissions from your State, as well as defining associated emissions strategies

to meet these goals, form the basis ofthe SIP process under the RHR.

In developing the statute's required Long Term Strategy (LTS), your State is offered

broad flexibility when determining reasonable progress goals and associated emissions.

As noted earlier, the RHR includes a requirement for States to assess a uniform rate of

progress and compare that rate to the reasonable progress goals set by those states with

Class I areas. We feel that this uniform rate of progress assessment is useful in

determining the geographic and economic extent a State can consider when developing

the LTS associated with the reasonable progress goals.

In general, we will be looking at the degree to which the LTS is supported by RPO

technical work and at the level of consistency among the contributing States. For Class I

areas where your State is setting a 2018 reasonable progress goal of equal or less

impairment compared to the uniform rate of progress, our review will focus holistically

on (1) whether strategies are applied equitably across source types, (2) ifboth local and

regional emission strategies have been fully examined, and (3) how consistent

assessments and strategies are applied regionally.

For Class I areas where the reasonable progress goal is more impaired than the uniform

rate of progress, consider presenting information on a component basis. Components

could consist of emission source category as before, but also include contributions from

individual pollutants or by geographic source area. Our intent is to better understand

where and why a strategy falls short ofthe uniform progress rate goal. Because each

region has focused their emission control strategy on different conditions, presenting

results in a component format may assist in showing what level of progress was made in

the focus area, verses other less controllable factors.

2
Wildland Fire

Your state has considerable flexibility as it addresses all anthropogenic sources of

visibility impairment, including fire. The RHR requires consideration ofsmoke

management techniques for agricultural and forestry management practices in the

development ofthe LTS part ofthe SIP. On a short-term basis,fire, both natural and

anthropogenic, has the potential to cause significant visibility reduction in Class I areas.

If anthropogenic fire contributes to the index used to track long-term, reasonable progress

in a Class I area, the visibility SIP should identify how it will be addressed. Your state

may already have a smoke management program (SMP) that adequately describes how

visibility impairment from fire will be addressed. Iffire has been determined to

contribute to visibility impairment, we suggest including a fire emissions inventory along

with a comment about its reliability and a projection for changes to the future inventory.

If your state has a SMP, is it a basic smoke management program or an enhanced smoke

management plan? And has the SMP been certified by EPA's Interim Air Quality Policy

on Wildland and Prescribed Fire? Identify the specific SMP requirements for minimizing

visibility impairment in Class I areas and classify the various types ofwildland fire

(wildfire, prescribed fire, and wildland fire use fire) as either natural or anthropogenic.

Are there differences in state regulation for the way in which smoke from agricultural

burning and forest fires are treated? Is there a difference in the way emissions from

wildfire, prescribed fire and wildland-fire-use (WFU) fire are identified and treated on

private, state and federal lands?

Regional Consistency

The RPOs have been working toward regionally consistent approaches to address

visibility impairment throughout the SIP development process. There may be

circumstances when different methods were used or impairment assessments reached

different conclusions. The FLMs understand that each State knows what emission

control methods or air quality management strategies work best for its areas. Each State

may wish to develop strategies that are independent from RPO or neighboring areas.

In this context, our review of "regional consistency" will have less to do with individual

discretion each State has in making decisions, and more on how well a group of States

identifies and addresses similar, agreed upon goals for each Class I area within a common

area ofinfluence.

Regional consistency can also be difficult to evaluate if neighboring SIPs (or portions of

SIPs) are released for review at different times. We expect that thorough inter-State

consultation processes will lead to consistent descriptions of apportionment and emission

control goals, thus resulting in development ofsimilar progress goals, regardless of

release dates.

Verification and Contingencies

Little emphasis has been placed in the RHR on verification and even less on contingency

planning. By rule, each SIP must identify the monitoring data used to specify the original

baseline and also as part of an ongoing progress review at five-year intervals. Given the

uncertain future of any individual monitoring site, we suggest that the SIP address the

representativeness of both primary and alternative data sites for each class I area.

3
Consider not only the data necessary to measnre progress but also how to account for and

mitigate both unexpected and reasonably foreseeable emissions growth, changes to the

geographic distribution of emissions, and substantive errors that may be found in

emission inventories or other technical bases ofthe SIPs, These factors, as well as other

unanticipated circumstances, may adversely affect yonr state's ability to achieve the

emissions reductions projected by the SIP, Considering these factors through adaptive

management or continual review strategies may assist in avoiding these circumstances,

Coordination and Consultation

The 1999 Regional Haze Rule requires States to consult with the Federal Land

Management (FLM) agencies at least 60 days prior to holding any public hearing on a

RHR SIP or SIP revision (40 CFR 5I.308(i», The federal land managers for each ofthe

88 Forest Service Class I areas are listed in attachment 2. As named in the cover letter to

this attachment, a single Forest Service air specialist has been assigned to your state. He

or she will facilitate the coordination of comments from multiple Forest Service FLMs if

they exist in yonr state.

4
I

I USDA United States

Department of

Agricnltnre

Forest

Service

Intermountain Region 324 251h Street

Ogden, UT 84401

801-625-5605

File Code: 2580

Date: October 31, 2008

Mr. David A. Finley, Administrator

Division ofAir Quality

Department of Environmental Quality

122 W. 25th Street

Cheyenne, WY 82002

Dear Mr. Finley:

The Forest Service (FS) has reviewed the Department of Environmental Quality'S (DEQ) Best

Available Retro-Fit Technology (BART) determinations for the BART-eligible emission units at

the FMC Granger AP-6044, FMC Westvaco AP-6045, and General Chemical Green River

Works AP-6046 facilities. The BART determination is a critical component ofthe EPA

Regional Haze program to improve visibility in our national parks and wilderness areas, of

which Regional Further Progress and the Long Term Strategy are also key components. As

such, the decisions made by the DEQ under the BART process may also affect the other program

elements affecting our nation's ability to improve visibility. With this broader perspective, the

FS offers the following comments on the DEQ's BART determinations.

Dispersion Modeling - Ozone Concentrations:

The FS is concerned that visibility impacts may be underestimated in the refined modeling, as

caused by an under-representation ofthe ozone concentration. The ozone data used in the BART

modeling is not believed to be spatially or temporally representative ofthe ozone concentration

ofa plume/pufftraveling from any ofthe BART-eligible emission sources near Green River

toward the Fitzpatrick and Bridger Wilderness areas. Emissions of air pollutants originating near

Green River must pass through the atmosphere near the Jonah and Wamsutter oil and gas fields

as they travel toward the Bridger and Fitzpatrick Wilderness areas. The ozone data used in the

modeling is from 200 I through 2003. In 200 I, there were reported 25,199 oil and gas producing

wells in Wyoming. By 2006, this number increased to approximately 38,000 wells state wide l

,

with associated increases in air emissions. In 2006, the first-ever winter time exceedance ofthe

ozone standard was experienced in Sublette County. Hence, hourly ozone data used in the

refined dispersion modeling for the BART analyses is not temporally representative.

Similarly, the spatial distribution ofthe ozone monitoring sites used in the BART modeling

analysis is suspect. Recent studies of monitoring locations in southwestern Wyoming have

certainly raised awareness ofthe complexity of addressing this issue. Unfortunately, the

Pinedale ozone monitoring site was not operating during this study period, so a direct

comparison is not possible..However, the area near South Pass appears to have higher ozone

1 Wyoming Oil & Gas Commission.

Caring for the Land and Serving People

,..,

Printed on Reoycled Paper ...,
Dyar Mr. Finley 2

concentrations than near Pinedale. As such, the FS is concerned that the ozone data used in the

BART modeling is not spatially representative.

The underestimation of ozone concentration affects the model-predicted haze impacts primarily

for nitrates, as follows. Ozone is the primary source of hydroxyl radicals (01-1), which playa key

role in the formation of ammonium sulfate [(NH4)2S04] and ammonium nitrate (NI-I4N03) in the

CALPUFF model. Ozone serves as the primary source of hydroxyl radicals, which react with

N02to form nitric acid. The nitric acid reacts with ammonia to form ammonium nitrate.

Figure 1 below illustrates the effect of ozone concentration on the formation of nitric acid

(RN03), which is also affected by PG stability class and N02 concentration. Underestimating

the ozone concentration by 20 ppb (e.g., 40 ppb instead of 60 ppb), may result in a 50 percent

underestimation in the conversion rate ofN02 to nitric acid, and effectively reduce the modelpredicted haze by half for a given hour.

Figure 1. Effect of Ozone Concentration on Nitric Acid

Conversion Rate of NOx to HN03

[NOx] =0.025 ppm

30.0 - -c

25.0

l: 'C 20.0

.~ 15.0

- 10.0

l:<3 5.0

0.0

0.01 0.03 0.05 0.07 0.09

-PGT=2

-PGT=3

PGT=4

Ozone Concentration (ppm)

To remedy this issue, the FS is requesting that Wyoming DEQ re-evaluate the more recent

hourly ozone data to ensure an appropriately representative value is used, and rerun the BART

dispersion modeling analysis.

Natural Background Concentration:

The DEQ states that "Species concentrations corresponding to the 20 percent best days were

calculated for each Class I area by scaling back the annual average concentrations given in Table

2-1 ofthe EPA document Guidance for Estimating Natural Visibility Conditions Under the

Regional Haze Rule." Additional information is needed to understand and evaluate the use of

scaling factors as applied to the alU1ual average concentrations for calculating background
Ollar Mr. Finley 3

concentrations for the 20 percent best days. As this information is used in the quantification of

change in light extinction, which is subsequently compared with thresholds of acceptance, a

thorough understanding ofthis approach is needed for concurrence.

USDA Forest Service Comments on BART Determination for FMC Granger

The FS understands that two BART-eligible units were evaluated and deemed exempt fTOm

BART based upon refined dispersion modeling. These two units are 358.5 MMBtu/hr coal-fired

boilers, each equipped with FGO scrubber and ESP controls.

Given the modeling concerns expressed above, the FS caunot concur with the OEQ's

determination that these BART-eligible units are not subject to BART at this time.

USDA Forest Service Comments on BART Determination for FMC Westvaco

Facility AP-6045

The FS has reviewed the OEQ's proposed BART determination for the three BART-eligible

emission units at FMC's Westvaco facility. We understand that one ofthese units, the naturalgas fired boiler (PH-3), has been determined not to be subject to BART based upon the results of

refined dispersion modeling. The remaining two units NS-IA and NS-IB, both coal-fired

boilers, are subject to BART.

In making its determination, the OEQ recognized and relied upon the fact that applying the

recently installed low NOx burners and OFA for NOx is sufficient to bring the model-predicted

98th percentile impact below the 0.5 ~dv threshold. As such, the OEQ recommends that no

additional controls are warranted.

The FS acknowledges this approach, as many BART-eligible sources are using federallyenforceable controls to reduce model-predicted impacts below the subject to BART thresholds.

However, recognizing that BART is one ofthree components ofthe Regional Haze Rule that the

State will use to achieve our national visibility goals, we encourage the DEQ to consider the

cumulative impacts ofseveral BART-eligible sources in the Green River area. Consider the

following discussion contained in the preamble to the Regional Haze Rule pp 39120-39121.

"In a regulatory context, we believe that a State's decision as to an appropriate thresholdfor

contribution could depend upon the number ofsources affecting a class I area, To illustrate, if

there were only one emissions source affecting visibility in a class I area, that source could have

a deciview impact only slightly below the perceptibility threshold with out contributing to

noticeable impairment. However, ifthere were 1000 sources each changing visibility by O. I

deciviews, the total impact would be a 10 deciview change in visibility. In this hypothetical

example, all 100 sources would be contributing in equal amounts to substantial visibility

impairment. "

Currently, there are two BART-eligible sources at the FMC Granger facility, three BARTeligible sources at the FMC Westvaco facility, and two BART-eligible sources located at
Dllar Mr. Finley

General Chemical Green River Works facility. Four ofthese seven sources have been

determined to be subject to BART, after refined modeling.

4

The current approach proposed by the DEQ is to reduce emissions from each subject to BART

source to controls, which reduce individual impacts from each source to just below the 0.5 L\.dv

threshold.

Our general comments regarding the dispersion modeling apply to this facility. As such, the

model-predicted impacts may be underestimated, which ifthis is the case, would warrant further

emission reductions.

As already identified by the US Department ofInterior, the costs for implementing controls

beyond the minimum proposed by the DEQ are reasonable. Upon consideration ofthe

cumulative impacts from these sources, additional controls implemented at this time will help the

DEQ move closer toward its reasonable progress goals. Hence, whether these controls are

implemented as part ofBART or under Reasonable Further Progress, such controls are viewed as

reasonable.

S02 Controls:

The S02 controls identified for the two coal-fired boilers in DEQ's analysis are limited for two

options for increasing the amount of gas routed exhaust through the wet scrubber. However, the

EPA BART rule identifies several other wet scrubber upgrade options, which are not currently

addressed in the DEQ's analysis. These additional upgrade options include installation ofliquid

distribution rings; installation of perforated trays; use of organic acid additives; improve or

upgrade scrubber auxiliary system equipment; and redesign spray header or nozzle configuration.

Each ofthese upgrade options should be considered in the BART analyses.

Analysis of Control Technologies in the Visibility Modeling:

In evaluating the effectiveness ofthe various control options in reducing haze, it would be

helpful ifthe modeling results were presented for the combination ofLNB/OFA/SNCR (NOx)

and scrubber upgrades, both without and with a new bypass (S02).

BART Determination:

The DEQ determined that the installation of low NOx burners with enhanced OFA meeting NOx

emission limits of 0,35 Ib/MMBtu (30-day rolling average), represents BART for each ofthe

coal-fired boilers. The DEQ states that this determination is based on the results ofthe visibility

analysis, which show that FMC's proposed BART control option results in an average reduction

of 0.3 L\.dv in the 98th percent result at Bridger Wilderness Area as compared to the baseline

condition for each unit, and a reduction of 0.2 L\.dv in the 98th percent result at Fitzpatrick

Wilderness Area compared to baseline conditions. The 98th percentile values for both units

NS-IA and NS-IB were below 0,3 L\.dv increase from background conditions for all 3 years of

meteorology.
D~ar Mr. Finley 5

This determination is based upon considerations ofthe model-predicted change in deciviews

compared to baseline conditions. EPA states in the preamble to its BART Guideline2that "Even

though visibility improvement from an individual source may not be perceptible, it should still

be considered in setting BART because the contribution to haze may be significant relative to

other source contributions in the Class I areas." Given the proximity ofthe two boilers, the

combined effect ofrequiring more stringent controls, such as LNB/OFA with SNCR, will likely

allow the State to reach its reasonable progress goals

USDA Forest Service Comments on BART Determination for General

Chemical Green River Works AP-6046

The FS has reviewed the DEQ's proposed BART determination for the two BART-eligible

emission units at General Chemical Green River Works. We understand the two units are

tangentially fired boilers using in-line pulverizers to burn low sulfur subbituminous coal, which

supply power and process steam to the mining and ore processing operations. Boiler C has a

firing rate of 534 MMBtu/hr and Boiler D has a firing rate of 880 MMBtu/hr. Each boiler is

currently equipped with a hot-side ESP to control particulates, overfire air and low excess air

used to reduce NOx, and no add-on controls for S02. Our comments are presented below.

Dispersion Modeling:

Please refer to our previous comments on ozone concentrations and use ofscaling factors for

determination of background concentrations.

Effectiveness of Control Technologies: NOx

In its preamble to its BART Guidelines, EPA states, "Many control techniques... can perform at a

wide range of levels.. .It is important, however, that in analyzing the technology, you take into

account the most stringent emission control level that the technology is capable of achieving."

The DEQ identifies the effectiveness of NOx controls as follows: low NOx burners (LNB) with

separated overfire air (SOFA) achieve 30 percent control; SNCR achieves 50 percent control,

and SCR achieves 80 percent control. Lower NOx emission rates are achievable.

Low NOx burners with advanced over-fire air, tangentially-fired boilers are able to achieve NOx

emission rates between 0.14 and 0.39 Ibs/MMBtu (equivalent to 20-77 percent contrail Similar

emission rates were found in the NETL coal plant database. For example, the Ameren Rush

Island Facility in Missouri is able to achieve annual average NOx emission rates of 0.089

Ibs/MMBtu, and 0.0941bs1MMBtu for its two boilers. Ameren's Newton, Illinois, facility is able

to achieve an annual average NOx emission rate of 0.136 Ibs/MMBtu. SNCR alone can achieve

between 30-50 percent reductions in NOx4

. SCR can achieve up to 90 percent reductions.

2 Federal RegisterNo!. 70 No. 128/Wednesday, July 6, 2005. Page 39129

3 Aistom TFS 2000R Low NOx Control Systerm

4 U.S. EPA Ail' Pollution Control Technology Fact Sheet: Selective Non-Catalytic Reduction. EPA-452/F-03-031.

5 U.S. EPA Ail' Pollution Control Technology Fact Sheet: Selective Catalytic Reduction: EPA-452/F-03-032.
D~ar Mr. Finley 6

The use oflower than best achievable control effectiveness results in lower model-predicted

reductions in haze, and therefore potentially affects the determination of BART.

Costs:

The costs for applying each ofthese control technologies is higher than typical cost ranges. For

example, ultra low NOx burners with advanced over-fire air, tangentially-fired boilers cost

between $300 and $1200 per ton, whereas the costs are estimated at $1332 per ton for Boiler C

and $1433 for Boiler D.

Typical SNCR costs are $500 - $1500 per tonG, whereas the proposed costs are estimated at

$2712 per ton for Boiler C and $2025 per ton for Boiler D.

Western Backstop Sulfur Dioxide Trading Program:

The DEQ has stated that "General Chemical will not be required to meet either proposed

emission limit under BART. Instead, General Chemical will be required to participate in the

emissions trading program under Chapter 14 ofthe WAQSR should the program be triggered."

Under 40 CFR 51.309 (g)(2)(ii), the requirement under 51.308(e) related to BART for regional

haze is deemed to be satisfied for pollutants addressed by the milestones and backstop trading

program if, in establishing the emission reductions milestones under paragraph 40 CFR 51.309

(d)(4), it is shown that greater reasonable progress will be achieved for these additional Class I

areas (e.g., Fitzpatrick and Bridger Wilderness Areas) than would be achieved through the

application ofsource-specific BART emission limitations under 51.3 08 (e)(I). Additional

information supporting this demonstration is required, otherwise the S02 emission limits

established under BART will be in effect.

We appreciate your consideration ofthese Comments. Should you have questions regarding

these comments please contact Bud Rolofson, FAA Staff, at (303) 275-5752.

Sincerely,

lsi Brent Larson (for)

HARV FORSGREN

Regional Forester

cc: Mike Dudley

Bud Rolofson

Jeff A Sorkin

RickGraw

Scott A Copeland

Ann Acheson

6 Midwest RPO Interim White Paper - EGUs. March 2006
USDA United States

Department of

Agricnlture

Forest

Service

Rocky

Mountain

Region

740 Simms Street

Golden, CO 80401

Voice: 303·275·5350

TDD: 303·275·5367

File Code: 2580

Date: July 21,2009

David A. Finley

Air Quality Administrator

Wyoming Department of Environmental Quality

122 West 25th St.

Cheyenne, WY 82002

Dear Mr. Finley:

The Forest Service (FS) has completed its review ofthe best available retrofit technology

(BART) materials for the BART-subject electric generating units (EGUs),Jim Bridger and

Naughton power plants posted on the Wyoming Department of Environmental Quality (WDEQ)

website. The FS concurs and supports the review and findings ofthe U.S. Department of

Interior, National Park Service, and Fish and Wildlife Service regarding BART materials

submitted for the Dave Johnson, Laramie River, and Wyodal( EGUs.

These BART determinations are a key part ofthe regional haze plan the State of Wyoming is

preparing. This plan will demonstrate how Wyoming will make reasonable progress toward

meeting the national goal of preventing any future, and remedying any existing, impairment of

visibility in mandatory Class I areas. The regulations describing what these plans should contain

are found at 40 CFR 51.300 through 309. As the Federal Land Manager (FLM) for the North

Absaroka, Washakie, Teton, Fitzpatrick, Bridger, Savage Run, Mount Zirkel, Rawah, Flat Tops,

and Eagles Nest Class I Wildernesses, we are very interested in these BART determinations and

the Wyoming Regional Haze Plan as a whole.

The regional haze regulations at 40 CFR 51.308(i) require consultation between the FLMs and

the State. Specifically, the FLM is to receive 60 days to review and comment on any plan or

plan revision. The State must also include a description of how it addressed the FLM comments

ifthey are received in the specified timeframe.

As you know, the BART determination must consider the "best system of continuous emissions

control technology" taldng into account the following factors: "the technology available, the

costs ofcompliance, the energy and non air quality environmental impacts ofcompliance, any

pollution control equipment in use at the source, the remaining useful life ofthe source, and the

degree ofimprovement in visibility," 40 CFR Section 51.308(e)(I)(ii)(A).

Our review ofthe five statutory factors leads us to the conclusion that selective catalytic

reduction (SCR) should be BART for nitrogen oxides (NOx) for all units at both the Jim Bridger

and Naughton power plants. We applaud the State of Wyoming for proposing to install SCR at

the 4 units at the Jim Bridger EGU. The FS believes the installation timeframe for SCR should

be within the 2015-2016 timeframe for all four units at the facility.

It's Cool to Be Safe

,...

Printed on Recycled Paper ..,
David A. Finley, WDEQ

The FS believes that the already-permitted installation ofwet flue gas desulfurization (FGD)

equipment for the Jim Bridger Power Plant Units 1-4 should be BART. Similarly, the FS

believes that the installation ofwet FGD equipment for the Naughton Power Plant Units 1-3

should be BART.

2

The United States Forest Service compliments you on your hard work and dedication to

significant improvement in our nation's air quality values and visibility. Cooperative efforts

such as these ensure that, together, we will continue to malce progress toward the Clean Air Act's

goal of natural visibility conditions at our Class I wilderness areas and parks. We appreciate the

opportunity to continue to work closely with your agency as you develop final BART

determinations for these facilities. If you have questions or comments, please contact Jeff

Sorkin, at (303)-275-5759.

Sincerely,

/s/ Rick D. Cables

RICK D. CABLES

Regional Forester

Rocky Mountain Region

Enclosures

cc: Jeff A Sorkin

Ann Acheson

Trent R Wickman

Terry Svalberg

Scott A Copeland

Bruce Polkowsky

Don Shepherd

Dean Gillam

/s/ Harv Forsgren

HARV FORSGREN

Regional Forester

Intermountain Region
United States Forest Service Technical Comments

Wyoming BART determinations for Jim Bridger and Naughton Power Plants

The units under consideration are four 530 MW units (numbered 1 through 4) at the Jim Bridger

power plant and 3 units at the Naughton power plant; 160,210,330 MW respectively for units 1

through 3.

Overall Comments:

The FS commends PacifiCorp and the Wyoming DEQ for the strong NOx controls proposed for

BART and reasonable progress. We believe the proposed controls will significantly improve air

quality in the many Class I areas surrounding the facilities. While we do not agree with every

conclusion, the BART documents are thorough and well written.

Demonstration of the Extent of Visibility Impacts:

PacifiCorp modeled visibility improvements from proposed BART and reasonable progress

controls. The FS feels it is important to document visibility impacts to Class I areas as

completely as possible in order to place in context the total benefit derived from controls. Then,

the cost of each BART alternative should be divided by the sum ofthe deciview improvement at

all impacted Class I areas to determine the cost per deciview. This may result in acceptance of a

previously discarded control alternative due to the showing of a reasonable cost of visibility

improvement.

As such, the FS would like to see visibility benefit modeling for all Class I areas within 300km.

(see maps attached.) Additionally, since there are Class I areas just beyond 3001an, if any

modeling already exists showing visibility improvement benefits greater than 0.5dv beyond

300km, the FS requests that information be included as well.

The State of Wyoming has determined that the Savage Run Wilderness Area will be managed as

a Class I airshed. Therefore, the FS would like the Savage Run Wilderness Area to be treated as

such in all Regional Haze planning including this BART review.

Pages ES-5 and 5-10 ofthe PacifiCorp BART Analysis discuss "Just-noticeable difference in

atmospheric haze" indicating that minimal, if any, observable visibility improvements at the

Class I areas would be expected under any ofthe control scenarios. It is incorrect to dismiss a

control strategy on the basis that the resulting improvement is not perceptible or significant. EPA

states in the preamble to its BART Guidelines:

"Even though the visibility improvement/rom an individual source may not be

perceptible, it should still be considered in setting BART because the contribution to haze

may be significant relative to other source contributions in the Class I areas, Thus, we

disagree that the degree 0/impairment should be contingent upon perceptibility, Failing

to consider less-than-perceptible contributions to visibility impairment would ignore the

CAA's intent to have BART requirements apply to sources that contribute to, as well as

cause, such impairment.,,3
Five Factor Analysis for BART Selection:

In the BART determination the State of Wyoming discusses the applicability of presumptive

BART to units at the Jim Bridger and Naughton power plants. EPA's view of presumptive limits

for S02 and NOx for EGUs are that they are "highly cost effective." EPA goes on to say:

"States, as a general maUer, must require owners and operators ofgreater than 750 MW

power plants to meet these BART emission limits. We are establishing these requirements

based on the consideration ofcertain factors discussed below. Although we believe that

these requirements are extremely likely to be appropriate for all greater than 750 MW

power plants subject to BART, a State may establish different requirements ifthe State

can demonstrate that an alternative determination isjustified based on a consideration of

the five statutory factors.,,4

So although the presumptive requirements are "extremely likely to be appropriate" a State can

demonstrate otherwise based on the five statutory factors. The FS believes that the analysis of

coal composition is not only flawed in its conclusions, more principally, it does not meet the

requirement for a demonstration ofwhy presumptive limits cannot be reached.

NOx Controls:

The FS sees the information presented as supporting SCR as BART for all units at both Jim

Bridger and Naughton power plants.

The State of Wyoming lists the following reasons for not installing SCR as BART on the 4 units

at the Jim Bridger power plant and units 1 and 2 at the Naughton power plant:

I) "The cost ofcompliance for installing SCR on each unit is significantly higher than LNB with

separated OFA."

2) "Combustion control using LNB with separated OFA does not require non-air quality

environmental mitigation for the use ofchemical reagents (i.e., ammonia or urea) and there

is a minimal energy impact."

However, the FS believes SCR is BART for all units at bothfacilities. The State of Wyoming

appears to concur with this finding because, in the determination, the State says "The cost

effectiveness and incremental cost effectiveness ofthe four proposed BART technologiesfor NOx

are all reasonable". In addition, FS is confused as to why Wyoming determines SCR as BART

at unit 3 at the Naughton Power Plant at $283Olton but for unclear reasons not at the other six

units with costs from $2258 - 2848/ton.

The FS would like to point out that SCR is a mature technology. We are unaware of any

environmental degradation due to a properly operated SCR. Furthermore, our inspection ofthe

cost analysis leads us to believe the energy impact associated with operating SCR is included in

the cost analysis, which makes this point raised by the State moot.
For the Jim Bridger Power Plant units, the State of Wyoming indicates:

"The cumulative 3-year averaged visibility improvementfrom Post-Control Scenario A

across the three Class I areas achieved with Post-Control Scenario B was 0.627 LJdv per

unitfrom Units 1-3 and 0.635 LJdv from Unit 4."

This statement makes the case that SCR would result in a significant improvement in visibility,

Each unit by itself improves visibility by an amount that results in "contribution" to visibility

impairment Le, it exceeds 0.5 dv, The total benefit of SCR on the four units (-2,5dv) easily

exceeds the threshold for "causing" visibility impairment, 1.0dv,

Similarly, for the Naughton Power Plant units, the State of Wyoming indicates:

"The cumulative 3-year averaged 98th percentile visibility improvementfrom PostControl Scenario A across both Class 1areas achieved with Post-Control Scenario B was

0.405 LJdv from Unit 1 and 0.506 LJdv from Unit 2,"

Again, the FS sees this fact as making the case that this is a significant improvement in visibility,

Each unit by itselfimproves visibility by an amount that results in, or approaches, a

"contribution" to visibility impairment. The total impact of SCR on the two units approaches the

threshold for "causing" impairment.

Regarding SCR in the BART phase ofthe analysis, Table 7 ofthe Wyoming BART Application

Analysis shows a removal efficiency of 84.4 percent for LNB/OFAISCR to reach 0,07

Ib/MMBtu, PacifiCorp and Wyoming have underestimated the ability of modern NOx control

systems. SCR has been retrofitted to many eastern pulverized coal boilers that are now

achieving 0,05 Ib/MMBtu on a 30-day rolling average basis. It is likely that many ofthese

EOUs are burning eastern bituminous coals with higher fuel-bound nitrogen than that burned at

the Jim Bridger Power Plant. Because "fuel nitrogen can accountfor up to 80 percent oftotal

NOxfrom coal combustion" it should be easier for PacifiCorp to achieve lower NOx emissions

than an EOU burning coal with higher fuel-bound nitrogen, If SCR is capable ofreducing

emissions below PacifiCorp's target, then the amount ofthe reductions and consequent visibility

improvements will increase. These greater efficiencies should be factored into the cost and

visibility analyses.

Reasonable Progress Controls:

The FS requests clarification as to why units I & 2 at the Naughton Power Plant are not required

to install SCR as part ofreasonable progress like the other five units.

802 Controls:

The FS believes that the already-permitted installation ofwet FOD equipment for the Jim

Bridger Power Plant Units 1-4 should be considered BART. Similarly, the FS believes that the
installation of wet FGD equipment for the Naughton Power Plant Units 1-3 should be considered

BART.

There appears to be an error in the analysis for unit 3 at Naughton. The performance ofthe wet

FGD was stated to be 0.10 IblMMBtu (Table 18) but the cost effectiveness analysis was done

based on O.l5Ib/MMBtu (Table 24). The cost per ton for S02 reduction should be calculated

using 0.10 IbIMMBtu, ifthat is the correct value.

The FS understands the role ofsection 309 in exempting the State of Wyoming from BART and

reasonable progress controls for S02 based on the demonstration in WRAP Technical Support

Document! that the S02 emissions reductions benefits under section 309 exceed those that would

have resulted from BART. Further we understand that the State of Wyoming has met it targets

under the 309 program. The FS would like to know ifthe controls in place at the Naughton and

Jim Bridger Power Plants are at least equivalent to the control scenario used in the demonstration

report. In other words, are the existing S02 controls actually as needed to accomplish the "better

than BART" demonstration?

The FS also notes that the 309 program sunsets in 2018, and that additional S02 controls may be

appropriate for reasonable progress at that time.

Visibility Impairment:

US EPA BART guidelines2 state that 0.5dv "contributes" to impairment, and 1.0dv "causes"

impairment. The discussion from Ronald Henry is irrelevant and used in an improper context.

References:

1. WRAP Technical Oversight Committee, Regional Technical Support Documentfor the

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

2. 40 CFR Part 51, Appendix Y. U.S. Environmental Protection Agency, "Guidelines for

BART Detenninations Under the Regional I-laze Rule.", July 6, 2005, See FR Vol 70, No

128, page 39161.

3. See 40 CFR Part 51, Appendix Y. The U.S. Environmental Protection Agency finalized

it's BART Guidelines on June 15,2005, and published the preamble and final rule text in

the Federal Register on July 6, 2005. The rulemaking action added Appendix Y to Part

51, titled "Guidelines for BART Determinations Under the Regional Haze Rule." See

Preamble, 70FR30129, middle column.

4. Federal Register, 7/6/05, p.39131
Class I Areas within 300km of Naughton PP

;; • Naughton PP

, Class I Units

NPS

'. USFS

;. FWS ,
Class I Areas within 300km of Jim Bridger PP

".--.., Jim Bridger Distance l;t;~~.::,·,-,/

• Jim BrIdger PP

Clas$ 1Units

NPS

·111 USFS

III FWS
USDA United States

Department of

Agriculture

Forest

Service

Region 2

740 Simms Street

Golden, CO 80401

Region 4

324 25'h Street

Ogden, UT 84401

File Code: 2580

Date: October 21, 2009

David A. Finley, Air Quality Administrator

Wyoming Department of Environmental

Quality - Air Quality Division

122 W. 25th St., Herschler Building

Cheyenne, WY 82002

Dear Mr. Finley:

The Forest Service (FS) has completed its review ofthe Wyoming Regional Haze State

Implementation Plan (SIP). The FS concurs and supports the review and findings ofthe US

Department of Interior, National Park Service, and Fish and Wildlife Service.

This plan's intent is to demonstrate how the State ofWyoming will make reasonable progress

toward meeting the national goal of preventing any future, and remedying any existing,

impairment of visibility in mandatory Class I areas.

The regulations describing what these plans should contain are found at 40 CFR 51.300 through

309. As the Federal Land Manager (FLM) for the North Absaroka, Washakie, Teton,

Fitzpatrick, Bridger, Savage Run, Mount Zirkel, Rawah, Flat Tops, and Eagles Nest Class I

Wildernesses, the FS is very interested in the Wyoming Regional Haze Plan.

As you are aware, the regional haze regulations at 40 CFR 51.308(i) require consultation

between the FLMs and the State. Specifically:

The State must provide the Federal Land Manager with an opportunityfor consultation, In person

and at least 60 days prior to holding any public hearing on an Implementation plan (or plan revision)

for regional haze required by this subpart. This consultation must include the opportunityfor the

affected Federal Land Managers to discuss their:

(I) Assessment ofImpairment ofvisibility in any mandatory Class {Federal area; and

(Ii) Recommendations on the development ofthe reasonable progress goal and on the development

and Implementation ofstrategies to address visibility impairment.

Detailed comments on the SIP materials and related Best Available Retrofit Technology (BART)

materials are included with this letter, specifically, I) FS Comments on the Regional Haze SIP,

2) FS Comments on Non-EGU BART Sources, 3) FS Comments on EGU BART Sources, 4) US

EPA Comments on Reasonable Progress (for reference).

The FS compliments you on your hard work and dedication to significant improvement in our

nation's air quality values and visibility. Cooperative efforts such as these ensure that, together,

we will continue to malce progress toward the Clean Air Act's goal of natural visibility

It's Cool to Be Safe

*'"

Printed on Recycled Paper ..,
conditions at our Class I wilderness areas and parks. We appreciate the opportunity to continue

to work closely with your agency as you develop this SIP. If you have questions or comments,

please contact Jeff Sorkin of our Rocky Mountain Region, at (303) 275-5759.

Sincerely,

/s/ Antoine 1. Dixon for

RICK D. CABLES

Regional Forester,

Rocky Mountain Region

cc: Jeff A Sorkin

Randy Karstaedt

Susan A Stewart

Terry Svalberg

Scott A Copeland

Ann Acheson

/s/ Jerome Perez for

HARV FORSGREN

Regional Forester,

Intermountain Region
U.S. Forest Service Detailed Comments: Wyoming RH SIP

October 7, 2009

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

the requested elements outlined in the FS letter submitted to Wyoming DEQ, dated 8/2006.

Nevertheless, 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 ofthe 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 Coal Review, Pinedale

Anticline, and others) identify potential ongoing visibility impacts in Class I areas within

Wyoming and in adjacent States such as South Dalwta and Colorado. The FS believes the

results ofthis modeling could benefit Wyoming in designing Reasonable Progress (RP)

strategies.

Chapters 4 and 5:

Tables 4.2-1 and 4.3-1 show projected decreases in overall state sox and NO, emissions.

However the same tables show increases in SOx emissions from Area sources and NO, emissions

from Area sources and Oil & Gas sources by 2018. The subsequent PSAT model results

(Figures 5.2.1-1, etc.) show increases in sox impacts from Wyoming on the best and worst 20%

days at all Wyoming Class I areas. The PSAT model also shows increases in NOximpacts on the

worst 20% days at YELL and BRID, and best 20% days at BRID. The FS understands that the

PSAT modeling was done early in the RH SIP process and relies on emissions inventories that

do not include all emissions reductions sought by Wyoming. Nevertheless, Wyoming is required

to demonstrate that the State is obtaining "its share o/the emission reductions needed to meet the

progress goal/or the area", per 40 CFR 51.308 (d) 3. While the FS acknowledges that

Wyoming may be meeting this requirement through the RH SIP, the FS does not find such a

demonstration in the SIP draft.

The FS requests that the SIP address in more detail the seasonality of potential effects on both

the best and worst 20% days at all Wyoming Class I areas as this could affect decisions for

emission reductions.

Chapter 6

The FS acknowledges Wyoming's involvement in the SO, backstop trading program, and the

corresponding regional S02 emissions reductions. 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 beyond the deadline for the initial non-EGU BART comment period. FS intends
that the non-EGD 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 EGD BART determinations for completeness.

Chapter 7

The FS concurs with EPA Region 8 in its letter dated August, 12,2009, in that Wyoming's 309

status does not absolve Wyoming ofits requirement to perform reasonable progress analyses for

S02 at Class I areas that are not part ofthe 16 Colorado Plateau Class I areas.

Wyoming has not demonstrated that its plan represents greater visibility improvement than is

expected to result from implementation of other requirements ofthe 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 ofother requirements ofthe CAA during the applicabie

planning period.

For example, Table 4.3-1 lists roughly 24,000 tons per year (TPY) of increase in NOx emissions

from Area and Oil & Gas sources, and roughly 7,000 TPY ofNOx reductions from BART point

sources. (It is noted that point source BART NOxreductions may actually be much larger.) The

additional reductions ofroughly 50,000 TPY come from mobile source rules which would be

counted as "other requirements a/the CAA". Not counting the mobile NOxreductions,

Wyoming has chosen a reasonable progress goal that may be a net addition ofNOx, and may

represent "less visibility improvement... " depending on the locations of new sources and

locations ofthe "reduced" sources relative to the Class I Areas.

The use of a Q/d screening tool for evaluating reasonable progress controls seems appropriate for

large stationary sources. FS recommends the SIP include a list of all sources considered by

Wyoming and the corresponding Q/d ratios (not just those with Q/d>10).

From the 309 (g) Technical Support Document on the Wyoming DEQ website, this table lists

sources with Q/d >1O. Please add to this table the identification of which sources were

controlled, by what technologies, and whether under BART or Reasonable Progress.
PoInt Sources With OlD Greater Than 10

PlilntName

MOUNTAIN CEMENT CO

PACIFICORP~WiODAK (SubJect to BARn

PACIFICORP~DAVE JOHNSTON

PAGIFICORP_DAVE JOHNSTON

PAGIFICORP_DAVE JOHNSTON (SubJeI;t to BARn

PACIFICORP_DAVE JOHNSTON (SubJoct to BART)

PACIFICORP_NAUGHTON POv'llE:R PLANT (SUbject to BART)

PACIFICORP_NAUGHTON POWER PLANT (Subject to BART)

PACIFICORP_NAUGHTON POWER PLANT (SubJl'oCt to BART)

BASIN ELECTRIC~LARAMIE RIVER STATION (SubjecttQ BART)

BASIN ELECTRIC_LARAMIE RIVER STATION (Subjtl<:ttQ BARTl

BASIN ELECTRIC~LARAMIE RIVER {;''TATION {SubJtld I(i BARTl

FMC CORP GREEN RIVE;R PLANT_SODIUM PROD (SubJe-ct to BART)

FMC CORP~GREEN RIVER PLANT_SODIUM PROD ($llbjact to BARTj

PACIFICORP_JIM BRIDGER (Subject 10 aAIU)

PACIFICORP_JIM BRIDGER (Subject to BART)

PACIFICORP_JIM BRIDQER(Stlbjectto BART)

PACIFICORP_JIM BRIDGER (Subject to BART)

'Not Fsderal M'llldatory Class I Area

Section 7.3.3:

County

Albany

Campbell

Converse

Converse

Converse

Converse

Llnooln

Linooln

LintXIln

Platte

Platte

Plalle

SWeetwater

SWeetwl:lter

Sweetwater

sweetwater

SWeetwater

Sweetwaler

Aug-09

Distance to Nearest Class \

NO/{ {tpy) Areil (kilometers) QlD Clllss I ArOIl Reference

1896.63 69 27.48738478 ROlWllh Wilderness (CO)

5213.72 169 30.85041539 Northern Cheyenne (MT)'

2265,69345 198 11.44290 Wind Cave (SO)

2174,17597 196 10,96069 Wind Cave (SO)

5002,41749 196 25,26473 Wind Cave (SOj

5337,88049 198 26,95899 Willd C,IVE! (SO)

5819.14354 75 77.58856 Bridger Wilderness rN'f)

4731.26053 75 63.06374 Bridger Wilderness rN'f)

3798.40423 75 50.64539 Bridger Wildemess (Wi)

6245.13706 202 30,511652 Rawah \lVilclerness (CO)

5999.89431 202 29,70245 Rawah \lVilderness (CO)

6309.22827 202 31,23380 Rawah Wildarness (CO)

1738,89Q54 138 12,60066 BridgerVv1lderness ryN)

1626,16452 138 11,77656 Bridger Wilderness ryvY)

1077970520 113 95.39562 Bridger \lVildernesa ry.N)

9853.98238 113 87,20338 Bridger Wilderness (WY)

10077.32077 113 89.17963 Bridger Wilderness (Wi)

9889.16059 113 87.61470 Bridger Wilderness (WY)

When citing cost effectiveness value, such as in regard to low-NO, burners with or without

overfire air, please reiterate that lower values are considered more favorable.

Section 7.6:

While four-factor analyses are presented for many source categories 1

,2 with direct relevance to

Wyoming (e.g. cement kilns and oil and gas development), Wyoming has proposed RP

reductions for only two large EOU BART sources, which results in RP goals well below the

Uniform Rate ofProgress (URP). Section 7.6 lists many reasons why Wyoming considers its RP

goals to be reasonable, however none appear to be related to the four factors in 40 CFR

51.308(d)(I)(i)(A), which are required to be considered in making the determination ofRP goals

below the URP.

40 CFR 51.308 (d) (1) (ii) "the State must demonstrate, based on the factors in

paragraph (d)(l)(t)(A) ofthis section, that the rate ofprogressfor the

implementation plan to attain natural conditions by 2064 is not reasonable; and that

the progress goal adopted by the State Is reasonable."

The FS understands that Wyoming is waiting for rulemaking "to obtain authority to further

evaluate non-BART sources", and that the expectation is that the State will have this authority in

2013. In the absence ofthe four-factor demonstration referred to above, the FS concludes that

Wyoming's proposed RP goals are not sufficiently justified.

Section 7.6 - Additional Items:

1. Neff, et al. 2008, suggest that roughly 75% of windblown dust is attributable to human

activity. As such, our understanding is that it is not appropriate to use windblown as a reason for

failure to achieve the 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 consider visibility impacts (e.g. $/dv) when determining

control strategies.

ChapterS

While tables 8.1.2.I-I & 8.1.2.1-2 do an adequate job of demonstrating impacts from Wyoming

emissions on surrounding States' Class I areas, the documentation ofthe projected impacts from

Wyoming emissions on surrounding States' Class I areas in the future is only available in the 309

(g) Technical Support Document. The FS understands that these proj ections may be incorrect

due to outdated emissions inventories; however, a projected increase in Wyoming's impacts at

other States' Class I areas is a salient point that deserves mention in the SIP itself.

The FS believes that 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 daily

contributions could be much higher. In other words, impacts from Wyoming could be very large

on an episodic basis. Further, projections offuture increases in Wyoming NO, impacts, (as

shown below for best days at Mount Zirkel Wilderness) could significantly increase Wyoming's

share ofimpacts even as surrounding States try to meet their reasonable progress goals.
Wyoming Nltl'1lt~ Contribution to Mount ZI rk~1
P.130 indicates: "By 2018, NOxemissionsfrom Wyoming are projected by the WRAP to

decrease by 39,861 tons, which will help reduce Wyoming's impact to out ofstate Class 1 areas."

While these emissions should decrease impacts on average, localized emissions increases could

clearly cause some Class I area impacts to increase.

The SIP proposes SCR for NOx control at Laramie River and Jim Bridger power plants as part of

the RP strategy. The FS supports these decisions.

Section 8.2.1.6 refers to tier 2 heavy-duty diesel equipment; however, manufacturers are

supposed to begin producing tier 4!transitional heavy-duty engines in the period 20II to 2014

and tier 4/final engines beginning in 2015. These changes in the manufacture of heavy-duty

engines will occur well within the planning period and should be acknowledged in the SIP.

Section 8.2.1.7.2 discusses the EPA's natural events policy of 1996. As of2007, this policy has

been superseded by an exceptional events rule under 40 CFR 50.13 (40 CFR 51 was also

affected by EPA's rulemaking). Wyoming maintains the natural events action plan that covers

portions ofthe Powder River Basin (PRB); however, exceptional events occurring in the PRB or

elsewhere now fall under the exceptional events rule.

Chapter 9

FS notes that Wyoming operates IMPROVE protocol samplers at Thunder Basin National

Grasslands and Cloud Peak Wilderness. FS finds this information useful and wishes to

acknowledge Wyoming's efforts. The FS also acknowledges 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.

Typographical Corrections:

Section 5.2.9. Should "Fine PM" be "fine soil"?

Table 7.3.4-1 Are the cost effectiveness values for selective non-catalytic reduction with urea

and ammonia correct? They appear along with unknown capital costs and annual costs for these

technologies as applied to the cement kiln.

Table 7.3.4-2 Column 3 - Potential Emission Reductions (1000 tons! yr). Should be TPY.

P167 . "In spite ofthe large number of growing uncontrollable sources in the WRAP region,

however, Wyoming does see a net visibility improvement at the Wyoming Class I areas through

2018." Should read "uncontrollable sources impacting the WRAP region... "?

Section 7.3.5 Please correct the typo on the acronym for air-fuel ratio controls (AFRC) in the last

sentence on page 122.
Chapter 8, p. 133 In the last sentence under the Bridger-Fitzpatrick nitrate section on page 133,

please revise the phrase "of at least 39,861 tons" to "by at least 39,861 tons."

References:

1. Supplementary Information for Four Factor Analyses by WRAP States May 4,

2009, ECIR Incorporated.

2. Supplementary Information for Four-Factor Analyses for Selected Individual

Facilities in Wyoming May 6, 2009, ECIR Incorporated.
Ref: 8P-AR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8

1595 Wynkoop Street

DENVER, CO 80202-1129

Phone 800-227-8917

hltp:lfwww,epa,gov/reglon08

AUG 122009

David A. Finley, Administrator

Division of Air Quality

Department'of Environmental Quality

122 W. 25th St, '

Cheyenne, WY 82002

Re: Preliminary Comments on WRAP's SourceSpecific Four-Factor Analyses for Reasonable

Progress in Wyoming

Dear Mr. Finley:

Please find enclosed EPA's preliminary comments on the draft Supplementary

Information for Four-Factor Analysesfor Selected Individual Facilities in Wyoming, dated

May 6, 2009. In addition, some ofthese preliminary comments pertain to the May 4, 2009, draft

Supplementary Iriformationfor Four Factor Analyses by WRAP States, although EPA has not

completed a fun review ofthis "general" report. These reports were prepared by,EC/R

Incorporated for the Western Regional Air Partnership (WRAP) anQ the Western Goverriors'

Association (WGA), We understand that you intend to use these reports to supplement the

State's Reasonable Progress analysis for the Wyoming Regional Haze SIP,

Please note these comments are highly preliminary, Given the nature of EC/R's fourfactor analyses and our uncertainty regarding their future use, we did not attempt to identify every

concern. Also, as you know, we will only reach a final conclusion regarding the adequacy of

Wyoming's Reasonable Progress analysis and Regional Haze SIP when we act on Wyoming's

Regional Haze SIP revision through notice and comment rulemaking,

Thank you for your considerations of our concerns, Ifyou have any questions, you may

contact me at (303) 312·6434, or your staffmay contact Amy Platt at (303) 312·6449,

Sincerely, .

4/C,c:f:~~ ~Videtich, Director '

Air Pro&Tam

Enclosure

ENCLOSURE

EPA Region 8 Preliminary Comments on the May 6, 2069, Draft .

Supplementary Information for Four-Factor Analysesfot

Selected Individual Facilities in Wyoming

• Region 8 is concerned that Wyoming's draft analysis does not consider any additional

S02 measures necessary for demonstrating Reasonable Progress (RP) for the additional

Class I areas, Specifically, on page I-I ofthe report, the contractor who developed the

report (EC/R Incorporated) states, "By request from the Wyoming state representative,

S02 has not beenanalyzed as S02 emissions have been addressed through the back stop

trading program." Wyoming is one offout states participating in the Regional Haze 309

program (the others include Arizona, NewiMexico and Utah). All ofWyoming's seven

Class I areas are offthe Colorado Plateau, and are referred to in EPA's regulations as

"additional class I areas." Section 51.309(g) does not exclude the 309 states that have

Class I areas offthe Colorado Plateau from addressing S02 under Reasonable Progress.

Specifically, 40 CFR 51.309(g) states the following: 51,309(g) Additional Class I areas.

Each Transport Region State implementing the provisions' ofthis section as the basis

for demonstrating RP for mandatory Class I Federal areas other than the 16 Class I

areas rnust include the following provisibns in its implementation plan. If a

Transport Region State submits an implementation plan which is approved by EPA as

meeting the requirements ofthis section, it will be deemed to comply with the

requirements for RP for the period from approval ofthe plan to 2018, .

(I) A demonstration of expected visibility conditions for the most impaired and

least impaired days at the additional mandatory Class I Federal area(s) based on

emissions projections from the long-term strategies in the implementation plan,

This demonstration may be based on assessments conducted by the States and/or a

regional planning body,

(2) Provisions establishing reasonable progress goals and implementing any

additional measures necessary to demonstrllte reasonable progress for the

additional mandatory Federal Class r areas. These provisions must comply

with the provisions of 51.3OS(d)(I) through (4).

(i) In developing LTSs pursuant to 51.308(d)(3), the State may build

upon the strategies implemented under paragraph (di of this section,

and take full credit for the visibility improvement achieved through

these strategies.

1 Paragraph d of this section includes requirements for the backstop trading program (BSTP),

1
The states' 309 SIPs must include provisions for establishing reasonable progress goals

and implement any additional measures needed to demonstrate RP for the Class I areas

offthe Colorado Plateau. [51.309(g)(2)1 The regulations provide that a state may take

credit for and build upon the strategies implemented underthe backstop trading program

(BSTP) in its RP analysis. However, the state must provide a demonstration in its SIP of

how the BSTP is meeting its visibility goals, and why S02 controls are not needed under

RP. Ifthe BSTP is not meeting visibility goals, then S02 controls must be evaluated

under RP.

• We have some overarching comments/questions related to this report as well as the

May 4, 2009, draft Supplementary In/ormation/or Four Factor Analyses by WRAP States

("General Report"). How did Wyoming select the sources to be analyzed? Howwere

certain emission units selected? What sources and source categories were found to

significantly impact visibility? You will need to discuss your selection criteria in the

Reasonable Progress section of the SIP and explain why the sources you select are the

appropriate sources to address under Reasonable Progress/Long-term Strategy

requirements. If the State does not address certaln sources or source categories, or elects

to defer some reductions to a future planning period, the State must provide adequate

justification and documentation for doing so. In addition, without knowing Wyoming's

uniform rate .ofprogress levels and how the EC/R reports will be used in Wyoming's SIP

effort, it is difficult to fully review the information presented. We will need to review

how the information from these reports is used in your SIP to determine adequacy.

• Wyoming included the two coal-fired boilers (Units BW4I & BW42) at the Pacificorp

Dave Johnston electric generating station, and the Mountain Cement Company Laramie

Plant cement kiln in its source specific four-factor analysis report. However, it is

unknown how Wyoming selected the sources that were evaluated, how the significance of

the sources was determined (e.g., Q/d threshold), and what criteria were used to cut off

other sources or source categories from evaluation. Wyoming should ensure that its SIP

includes a discussion ofthe methodology used to select sources, and why they are the

appropriate sources to address under Reasonable Progress/Long-term Strategy

requirements.

• Page 2-1, second paragraph: The RAC1'/BACT/LAER Cleannghouse is another source

ofinformation for potenti~l control technologies that the State should consult in

developing its SIP. Also, we have concerns with the secoild to last sentence ofthis

paragraph. Emission reduction requirements should be developed through the four-factor

reasonable progress analysis, not before the analysis occurs.

• Section 2.3, first paragraph, p. 2-2: The first line should read, "Table 2-1 summarizes the

energy and non-air quality related environmental impacts....."

• Table 2-1, p. 2-3: "Environmental Impacts" should be "Non-Air Quality Related

Environmental Impacts." Also, the first two items listed (waste generated and wastewater

generated) fall into typical categories ofimpacts evaluated under non-air quality related

2
environmental impacts, e.g., effects on the waste stream, water consumption" and/or

wastewater disposal. However, the remaillingfour types ofiInpacts listed donot fall into

these categories of hnpacts, and we recomtnend deleting them from evaluation.

• Pages 3-1 through 3-4 (Tables 3-1 through 3-4): Wyoming should include the NO,

Ib/MMBtu value for the Dave Jomston UJ1its, because control efficiencies and Costs

depend upon existing IblMMBtu emission rates.

• Page 3-2 (first paragraph): It is our understanding that cost information is already

available for larger sized boilers so there s!hould be'no need to extrapolate the capital cost

data. In addition, the annual capital cost should be calculated using a, Capital Recovery

Factor (CRF), which is added to, not multiplied by, the O&M costs. '

• Page 3-2, last paragraph, and Page 4-4, second paragraph: These timelines for

compliance for the boilers seem to be overestimated and/or don't account for steps that

could be completed in parallel. Similarly, an estimated seven years to control the

Mountain Cement Company's Laramie Cement Plant kiln is not realistic, and should be

shortened, as a kiln is nowhere near as complex as a power plant. 'In addition, the time,

necessary for compliance should not include time to develop regulations. If new

regulations are necessary, such regulationS should be submitted with the forthcoming SIP.

The statement that two years may be need~d to develop the rules to implement the

strategy implies that the State lacks authority to develop and supmit a SIP to address

Long-term Strategy and Reasonable Progress requirements, including relevant reasonable

progress measures.

• Page 3-2 (Table 3-2): The estimated control efficiency ranges do not appear to be

reasonable. It would better serve the reader to provide a best estimate of control

efficiency as a distinct number rather than' a range (while acknowledging that there is a

range of uncertainty around that estimate in the text or a footnote). For NO" we suggest

using 40% for LNB, 60% for LNB with OFA, 50% for SNCR, and 90% for SCR. It

should be noted that NO, controls can illso be used in combination, and the reductions

that result from using the control technologies in combination should also be evaluated

and may lower the overall $/ton numbers.

• Page 3-2 (Table 3-2): ECIR has calculated the emission reduction numbers using the

upper end ofthe control efficiency range, .which could be misleading. Again, a central

estimate (with upper and lower bounds noted) should be provided, with the tounage

reductions based on the best estimate.

• Page 3-2 (Table 3-2) and Page 3-3 (Table 3-3): EC/R has listed various control options

for use as individual control technologies. It should ,be noted that these controls can also

be used in combination, and the reductions that result from using the control technologies

in combination should also be evaluated. For example, you could instilll LNB, OFA,

SNCR, and SCR together (in 'series), which might lower the overall $/ton numbers.

3
• Page 3-3, second paragraph: In the first sentence, Wyoming should add SCR after

"SNCR," because both control options use compressors and 'steam to inject ammonia into

the flue gas. In the second sentence in this paragraph, the report states, "Installation of

SCR on an industrial boiler is not expected to increase fuel consumption." However, this

may not necessarily be true, due to the fact that the extent that power is used (i. e.

additional fan capacity to blow flue gas through the SCR catalyst bed), and that when

power is replaced by increased boiler capacity, additional coal would be burned. EPA

recommends modifying the statement, or removing it altogether. In addition, it should be

noted that catalysts are commonly regenerated not only to save cost, but also to eliminate

the waste stream associated with catalyst disposal, which this report should acknowledge.

• Page 4-1 (fourth paragraph): Coke should be added to the list offuels that may be used in

cement kilns.

• Page 4-3, last two paragraphs: The report indic\ltes that SCR reduces NO, emissions

from exhaust gases by converting NO, to nitrate. However, SCR does not convert NO, to

nitrate; itreduces NO. to nitrogen gas (N2).

• Page 4-5, first full sentence: The.report states, "There is also the additional burden of

getting rid offouled or deactivated catalyst from the system - often the PM control device

in the form of a fabric filter or electrostatic precipitator can achieve this goal." However,

in EPA's experience, one would not get rid ofa catalyst with a PM control device. As

noted above, catalysts are commonly regenerated to not only save cost, but also to

elhninate a waste stream, which this report should acknowledge.

• Page 4-5, section 4.4: The discussion on the remaining useful life indicates that the age

ofthe cement kilns was not available to WRAP's contractor. This information should be

obtained and included in the SIP. .

• Page 4-6 (Table 4-2): 'The controlled amounts listed inthe table for SNCR are incorrect;

they should be 262 tons/year. EPA believes that the SCR control efficiency should be in

the range of 80-90%, with corresponding controlled amounts. For example, using SCR

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

opinion, the cost effectiveness for low NO, burners (LNB) presented in this table seems

too high. We usually expect numbers between $500 and $1,000 per ton for LNB.

4

@Printed on Recycled Peper
IN ftFJlI.Y REFER TO

United States Department of the ,Interior

NATIONAL PARK SERVICE

Air Resources Division

P.O. Box 25287

Denver, CO 80225

1.1::::."'

~""\ TAKE PRICE'

INAMERlCA

October 21,2009

N3615 (2350)

David A. Finley, Administrator

Division of Air Quality

Department of Environmental Quality

122 W, 25th Street

Cheyenne, Wyoming 82002

Dear Mr. Finley:

On August 26, 2009, we received Wyoming's draft regional haze implementation plan

for review. We appreciate the opportunity to work closely with the State through the

initial evaluation, development, and, now, subsequent review of this plan. Cooperative

efforts such as these ensure that, together, we will continue to make progress toward the

Clean Air Act's goal of natural visibility conditions at all of our most pristine National

Parks and wilderness areas for future generations,

This letter acknowledges that the U,S, Department of the Interior, U.S. Fish and Wildlife

Service (FWS), and National Park Service (NPS) have received and conducted a

substantive review of YO\Jr revised proposed Regional Haze Rule implementation plan in

fulfillment of your requirements under the federal regulations 40 CFR 51.308(i)(2) and

51.309(g). Please note, however, that only the U.S. Environmental Protection Agency

(EPA) can make a fmal determination regarding the document's completeness and,

therefore, ability to receive federal approval from EPA,

As outlined in a letter to each State dated August J, 2006, our review focused on eight

basic content areas. The content areas reflect priorities for the Federal Land Manager

agencies, and we have enclosed comments associated with these priorities. Overall the

draft implementation plan was well organized and addressed all the key elements outlined

in our letter. We recognize Wyoming is committing to significant point source emissions

reductions, We have two primary concerns with the draft plan: I) the reasonable

progress analyses did not consider what S02 controls beyond th\lse incl\lded in the

Section 309 State Implementation Plan might be reasonable to address visibility

impairment at Class I areas outside the Colorado Plateau, and 2) the impacts ofincreases

in NOx emissions due to the oil and gas development activities, We previously

commented in a letter to you dated August 4, 2009, that we consider selective catalytic
"

2

reduction (SCR) technology to be best available retrofit technology (BART) for several

Wyoming facilities that are subject to BART under the regional haze rule.

We look forward to your response, as per section 40 CFR 51.308(i)(3). For further

information regarding our comments, please contact Pat Brewer of the NPS Air

R.esources Division at 303·969·2153, or Tim Allen ofthe FWS Branch of Air Quality at

303·914·3802.

Again, we appreciate the opportunity to work closely with the State of Wyoming and

compliment you on your hard work and dedication to significant improvement in our

nation's air quality values and visibility.

Sincerely,

J;::~ Chief, Air Resources Division

National Park Service

Enclosure

cc:

Callie Videtich

USEPA Region 8

1595 Wynkoop St.

Mail Code: 8p·AR

Denver, CO 80202·1129

Sincerely,

~}(Ji..;(;V

Sandra V. Silva

Chief, Branch of Air Quality

U.S. Fish & Wildlife Service
"

National Park Servi~e and U,S. Fish and Wildlife Servi~e Comments

Wyoming Draft State Implementation Plan for Regional Haze

O~tober 21, 2009

General Comments

Wyoming's draft State Implementation Plan (SIP) is well organized and addresses aU the key

elements of a regional haze SIP as outlined in our August 2006 letler to the states. Wyoming

(WY) applies Western Regional Air Partnership (WRAP) teclmical analyses to define current

and natural visibility conditions, emissions inventories, state and source-sector contributions to

haze at WY Class I areas, and visibility responSe to expected emissions controls by 2018, These

WRAP products provide the basis for WY's reasonable progress goals. Beyond the emissions

reductions modeled by WRAP, WY documents additional nitrogen oxides (NO,) emissions

reductions from Best Available Retrofit Technology (BART) and WY's long-term strategy. We

are pleased with WY's commitment to these reductions and recommend that the State highlight

total expected reductions in a summary table and summary discussion early in the document.

We are concerned that WY has relied on sulfur dioxide (S02) controls under the Section 309

State Implementation Plan to also cover all WY's obligations for S02 under the Section 309(g)

SIP. The 309 SIP applied to Class I areas on the Colorado Plateau. Because Class I areas in

WYand neighboring states are not meeting the uniform rate of progress, WY should also

consider as part ofits reasonable progress analyses if additional SOl controls would be warranted

for Class I areas not on the Colorado Plateau.

We are also concemed by the projected increases by 2018 in NO, emissions from oil and gas

activities. Because these activities are located near the WY Class I areas, these emissions

increases may be offsetting the benefits of tile significant NO, emissions reductions expected

from mobile and point sources distributed across the State. Several large oil and gas

development projects are being planned for southern and southwestern WY. Emissions from

these projects are likely not included in the WRAP Phase II projections. We recommend that

WY work closely with the oil and gas industry to improve the emission projections and to reduce

emissions growth from these projects.

In our previous comments on WY's BART determinations (letter dated August 4, 2009), we

recommended that additional fueilities could cost effectively utilize Selective Catalytic

Reduction technology to further reduce NO, emissions.
Spedfic Comments

Sections 2 and 3 effectively describe the WY Class I areas and the visibility monitoring data that

define the 20% worst and 20% best visibility days at these areas. The figures in Section 3 clearly

demonstrate that organic carbon matter is the largest contributor to light extinction on the 20%

worst days at the WY Class I areas and that sulfate (S04) is the second most important

contributor. Nitrate (N03), elemental carbon, and coarse mass are smaller contributors on the

20% worst days. Sulfate and nitrate have larger percentage contributions on the 20% best days.

It would be helpful to include in Section 3 a brief discussion of how light extinction and

deciview are calculated from IMPROVE measurements. (This discussion is actually provided on

pages 191 and 192 in Section 13; it would be helpful to move it to the introductory discussion in

Section 3.)

Section 4: Emissions Inventory

WY could improve the reader's understanding of the subsequent chapters by providing

additional emissions inventory data. WY reports emissions as calculated by the WRAP for the

WRAP 2002d and 2018PRPb inventories. It would be helpful to add the inventory tables for

WRAP 2002c and 2018 PRPa inventories for S02 and NOx, and to explain that these are the

basis for the CAMx PSAT source apportiomnent runs that are used in S!;ction 5 to define WY

contributions to S04 and N03 at WY Class I areas. WY should also clarify that the 2002d and

2018 PRPb inventories are us!;d in the WRAP CMAQ projections of progress by 2018 that are

presented in Section 5. Table 4,9-1 does indicate the differences between the two inventories

and pg. 47 does cit!; that additional information on the inventories can be found in the WY

r!;chnical Support Document. However, the inventories are so important to interpretation of

results in Section 5 that we recommend that WY provide the data in Section 4.

The majority of the NO, reductions projected for the 2018PRPb inventory (Table 4.3-1) are due

to reductions in the mobile onroad and nonroad sectors. Point source NO. reductions are roughly

7500 tons, while NOx emissions from oil and gas activities are projected to increase by 19,000

tOilS (132%), There is significant uncertainty in the oil and gas productions as WY is currently

reviewing proposals for several additional oil and gas projects that would increase emissions

beyond those estimated in the WRAP inventory.

Section 5: Source Apportionment and Regional HilZI: Modding

WY cites WRAP CAMx-PSAT anaIys!;s of contributions to S04 and NO} from different source

regions and CMAQ projections of 2018 progress. The inventories and models are subtly

different so there are subtle differences in the results between CAMx-PSAT and CMAQ. PSAT

is suggesting small increases in WY's contributions to S04 (Figures 5.2.1-1 through 5.2.1-3) and

N03 (Figures 5.2.2-1 through 5,2.2-3) by 2018 on the 20% worst days at the WY Class I areas.

Referring back to the 20 l8PRPa 802 inventory, there is actually an increase in SOz emissions

from point sources that is revised for the WRAP 2018PRPb inventory to a decrease in S02 point

source emissions. PSAT points out the importance oflocation ofNOx emissions, particularly at

the Bridger Wilderness Area. Oil and gas NOx emissions increases are occurring in

2
........... ' .. -_ ...--.... ---.- - ..

southwestern and central WY relatively near the WY Class I areas. NO, reductions from mobile

and point sources are more distributed across the state.

The Weighted Emissions Potential (WEP) analyses are appropriately presented and interpreted.

Organic carbon, elemental carbon, and particulate mailer (PM) are important contributors to light

extinction, but non-anthropogenic sources dominate and so WY has appropriately placed less

emphasis on these constituents in this SIP.

It would be helpful to discuss in Section 5 how relative response factors are calculated to project

future visibility,

CMAQ results indicate that extinction due to sulfate and nitrate will decrease slightly by 2018,

but the WY Class I areas wiU not achieve the uniform rate of progress.

As part of our ongoing consultation, on October 6, 2009, we consulted with WY staff by

teleconference. During our call, it became clear that WY is expecting NO, reductions by 2018

from BART and the long-term strategy that are not included in the WRAP PSAT source

apportionment and CMAQ modeling of progress by 2018. It is important to point this out in

Section 5 even if there are not modeling results to demonstrate the benefits of these additional

reductions.

Section 6: BART determination

NPS previously submitted comments that SCR would be cost effective as BART for NO,

emissions from additional BART-eligible Electric Generating Units (EGU). It would be helpful

to slate at the end of the section the cumulative NO, reductions expected from BART

implementation in WY.

Table 6.2-1 compares actual S02 emissions to S02 milestone commitments in the Section 309

SIP. The state should clarify if actual emissions or milestone commitments are used in the

WRAP 2018PRPb S02 emissions inventory. Actnal emissions are currently running much lower

than the milestone commitments.

Section 7: Reasonable Progress Goals

Section 7.5 (pg. 123) indicates that WY Reasonable Progress Goals (RPGs) for 20% Worst Days

IUld 20% Best Days for Wyoming Class I areas are based primarily on results of WRAP CMAQ

modeling for 2018. WY should clarify that RPGs listed in Table 7.5-1 are the results of WRAP

2018b modeling without any additional controls beyond WRAP 2018b modeling, Actual

reductions may be greater than those modeled.

Beclluse the WY Class 1 areas do not achieve the uniform rate of progress, WY's reasonable

progress analysis needs to consider S02 controls for facilities not already addressed in WY's

Section 309 SIP. The S02 reductions in the 309 SIP do not exempt WY from considering in this

309(g) SIP how the emissions reductions expected from the 309 SIP controls, plus additional

3
,,

S02 controls, could be targeted to protect Class I areas that are not on the Colorado Plateau.

The State could find that additional S02 controls may not be warranted, but that finding must be

based on an assessment of the reasonable progress factors noted in the EPA regulations. In

Section 7A WY clarifies that the S02 reductions under the 309 SIP are included in the WRAP

modeling. WY should also define the tons of S02 reductions expected under the 309 SIP. Table

4.2-1 suggests a net reduction of 22,000 tons S02 from all point sources by 2018, but that figure

appears to include more sources than those controlling under the 309 SIP.

Table 7.2-1 is not cited in the text of Section 7.2.

WY uses Q/d:: 10 as an indicator ofsources that should be considered under reasonable progress

for additional NO, controls. Without more specific guidance from EPA, there is precedence that

other states have used a similar approach to screen sources. Applying these criteria, two units at

Dave Johnson EOD, one unit at the Mountain Cement plant, and oil and gas exploration and

production are. identified for reasonable progress analyses. Highly cost effective NO, controls

were identified in all cases. The reader is referred to Section 8 to learn that WY does not have

regulatory authority 10 require controls on these sources. It would be helpful to provide this

information in Section 7 or at a minimum to refer the reader to the specific section (8.3.4) where

the outcome ofthe reasonable progress analyses is provided.

WY asserts that unifOlID rate of progress will not be met because much of the contribution is

from uncontrollable sources. We believe that WY should do more to adopt cost effective

controls for reasonable progress for those pollutants which WY can control.

Section 8: Long Term Strategy

WY identifies contributions to Class I areas outside WYand contributions of neighboring states

. to WY Class I areas. WY consulted with neighboring states through discussions in WRAP

workgroups. WY cites EPA efforts to address emissions from Canada, Mexico, and marine

shipping as evidence of progress on contributions from sources outside WY.

WY indicates that controls under Section 309 SIP will have greater beneftt at WY Class I areas

than the Class I areas on the Colorado Plateau. Nonetheless, WY needs to consider what

additional S02 controls not considered in the 309 SIP are feasible for the WYand neighboring

Class I areas,

Oil and gas development and production are important and growing sources ofNO, emissions in

WY. Therefore WY should work closely with the oil and gas industry to develop better

estimates of oil and gas NO. emissions growth. Projects currently under evaluation in southern

and southwestern WY (Pinedale, Hiawatha, Moxa Arch, Continental Divide-Creston, Oun

Barrel, Madden Deep, and Iron Horse) could signit1cantly increase NO, emissions beyond those

already projected in the WRAP Phase II oil and gas inventory.

4
, '

While WY is developing the regulatory authority to limit emissions for oil and gas activities, we

enCOlU"age the State to ask ind11stry to offset emissions prior to regulatory requirements. Ozone

nonattainment in the Sublette County area will require WY to develop NO, emissions reduction

strategies. Emissions offset requirements currently in place are a start.

Given that WY lacks regulatory authority for additional controls for non-BART sources, it is

important that WY revisit controls options in 2013.

Long-term control strategies at BART facilities are welcome. A table to support FiglU"e 8.3.6-7

would be helpful to understand the magnitude of expected emissions reductions from BART

implementation and under the long-term strategy. The table provided by WY after our call was

very helpful in understanding the sources of emissions reductions.

WY's long-term strategy includes discussion of existing programs, including EPA discussions

with Canada and Mexico over international emissions, existing WY control programs, natural

events plan, measures to mitigate impacts from construction activities, and Smoke Management

teChniques. We encourage WY to also consider cost-effective controls for point SOlU"ce

emissions of fine particles, the anthropogenic contribution to dust (fine PM and course PM), and

prescribed fire.

We ask that WY include in the discussion of New Source Review and Prevention of Signiticant

Deterioration requirements recognition of visibility improvement goals so that progress in

reducing emissions from existing sources is not offset by growth in new sources.

We look forward to continuing to work with WY to protect visibility and other air quality related

values in the Class I areas and the region.

5
i ,)

USDA United States

:rrnz=; Department of

Agriculture

Forest

Service

Rocky

Mountain

Region

740 Simms Street

Golden, CO 80401

Voice: 303·275·5350

TOO: 303·275·5367

Steven A. Dietrich

Air Quality Administrator

Wyoming Dept. of Environmental Quality· Air

Division

122 W. 25th St.

Herschler Building

Cheyenne, WY 82002

Dear Mr. Dietrich:

File Code: 2580

Date: December 3, 2010

The Forest Service (FS) has been made aware of proposed revisions to the Wyoming Regional Haze State

Implementation Plan (SIP). In the past, communication between the FS and the Wyoming DEQ about

regional haze SIPs has been adequate, however the FS has no records ofthe State of Wyoming contacting

us about this SIP revision. We ask to be provided with a full 60·day comment period, as is required in

federal regulation for all SIP revisions (see below).

This plan's intent is to demonstrate how the State of Wyoming will make reasonable progress toward

meeting the national goal of preventing any future, and remedying any existing, impairment of visibility

in mandatory Class I areas.

The regulations describing what these plans should contain are found at 40 CFR 51.300 through 309. As

the Federal Land Manager (FLM) for the North Absaroka, Washakie, Teton, Fitzpatrick, Bridger, Savage

Run, Mount Zirkel, Rawah, Flat Tops, and Eagles Nest Class I Wildernesses, the FS is very interested in

the Wyoming Regional Haze Plan.

The regional haze regulations at 40 CFR 51.308(i) require consultation between the FLMs and the State.

These provisions apply to 309(g) SIPs and SIP revisions. Specifically:

The State must provide the Federal Land Manager with an opportunity for consultation. in

person and at least 60 days prior to holding any public hearing on an implementation plan

(or plan revision) for regional haze required by this subpart. This consultation must include

the opportunityfor the affected Federal Land Managers to discuss their:

(I) Assessment ofimpairment ofvisibility in any mandatory Class I Federal area; and

(it) Recommendations on the development ofthe reasonable progress goal and on the

development and implementation ofstrategies to address visibility impairment.

The FS has conducted a cursory review ofthe 309 and 309(g) material dated October 21, 2010. We

request the full 60 days, through December 20'h, to complete a more thorough review. In the interim, we

can offer the following comments at this time regarding the 309(g) material:

I. In section 8.3.5, Wyoming indicates that the DEQ can't complete evaluation of oil and gas

contributions without the WRAP Phase III report. The FS understands that the Phase III work is

in progress for the Wind River, Upper Green River, and Powder River Basins. Completions of

these inventories are expected beginning July 2011. We look forward to Wyoming addressing

this important emission category when the Phase III report is completed; however, these repOlts

It's Cool to Be Safe Printed on Recycled Papar .:;
Steven A. Dietrich, WY-DEQ 2

apparently will not address oil and gas development in tlle entire State. Oil and gas activities

throughout Wyoming may significantly impact visibility in Class I areas in Wyoming and in other

states. Therefore, the FS requests that the efforts be expanded to include all potential visibilityimpairing oil and gas related emissions.

2. Figure 8.3.6-7 does not appear to reflect the changes in BART compliance dates.

The FS compliments you on your hard work and dedication to significant improvement in our nation's air

quality values and visibility. Cooperative efforts such as these ensure that, together, we will continue to

make progress toward the Clean Air Act's goal ofllatural visibility conditions at our Class I wilderness

areas and parks.

We appreciate the opportunity to continue to work closely with your agency as you develop this SIP. If

you have questions or comments, please contact Randy Karstaedt, Director, Physical Resources at (303)

275-5374, or by email atrkarstaedt@fsJed.us.

Sincerely,

lsiAntoine L. Dixon

ANTOINE L. DIXON

Deputy Regional Forester,

Resources

cc: Patricia F Brewer

Tim Allen