;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 ofa substantive review ofyour proposed Regional Haze (RH) Rule State Implementation Plan (SIP) revision, specifically; the 309 and 309(g) materials dated October 21, 2010. Please acceptthis letter and re-submittal ofprevious letters as FS comments on Wyoming's RH SIP. Thankyou for extending the Federal Land Manager (FLM) review period through January 6, 20II. This plan's intent is to demonstrate how the State ofWyoming will make reasonable progress toward meeting the national goal ofpreventing any future, and remedying any existing, impairment ofvisibility in mandatory Class I areas. The regulations describing whatthese 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, FlatTops, 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 ofnatural visibility conditions at our Class I wilderness areas and parks. We appreciate the opportunityto continue to work closelywith your agency as you develop this SIP. Ifyou have questions or comments, please contactRandy Karstaedt, Director, Physical Resources at (303) 275-5374, orby 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

MrDavid 

### 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: Overthe past several years, our staffhas participated with members ofyour staffand those ofneighboring 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 ofyour Regional Haze State Implementation Plan (SIP) is at hand, we want to work with you and your staffto help ensure thatyour 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. Ourfocus will be on Class I wildernesses for which the USDA Forest Service is responsible. We also have a coordination linkwith the other Class I area managers, the National Park Service and the US Fish & Wildlife Service, to facilitate to the extentpossible 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 expectto be able to share with you ideas from across the nation. As themanager ofeighty-eight Class I areas, we believe each state contributes to a national fabric ofemission 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 pertinentto SIP preparation. Any comments or questions aboutthese perspectives should be directed to Bud Rolofson, at (303-275-5752 brolofson@fsJed.us), your principle Forest Service point ofcontact 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 ourrecommendations.
Please identify the key point(s) ofcontact on your staffwith whom Bud may work on the SIP. Send all correspondence to both Bud Rolofson and Ann Mebane. We would preferthis 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 

### JeffA Sorkin

### Attachment Subject: Regional Haze Rule Consultation with the USDA Forest Service, July 2006 Thefollowingperspectives are merelysuggestions or recommendations notdirection or requirements. They are deliberately very similarto thosepreparedby the Department of Interior to contribute to a common sense of purposefor improving haze in all Class I areas. We are sending theseperspectives to each state. In so doing, we hope tofacilitate inter-state coordination. Atthe same time, wefully acknowledge the discretion afforded inthe RHRfor unique andcreative solutions by individualstates in writingplans that reduce haze. Natural Condition, and Uniform Rate These factors apply mainly to States thathave Class I areas. Other States that contribute to visibility impairment in Class I areas, located in adifferent state might consider including discussion and conclusions on these factors in their individual plans. The basic calculation ofbaseline, natural condition, and uniform rate builds the foundation for the entire RHR SIP process. Considerable discussion and debate atthe 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 adetailed description ofthe methods used in the SIP. Calculations thatinclude only portions ofestablishedmethods 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 Giventhe 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-yearinventory used to evaluate model performance; atypical, 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 inthe 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 ofyour emission inventory includes the implementation of"BestAvailable Retrofit Technology" (BART) on a subset ofpre-Prevention ofSignificantDeterioration sources. BART source identification, elimination, and level determination will be of particular interest for review. We would preferto see a clearprogressionthroughthe three basic BART phases and athorough description ofthe RHRprescribed factoranalysis (ifapplicable). Consider discussing whether BART levels apply to individual or grouped source categories. 

### Area oflnfluence The area ofinfluence ofsignificantvisibility-impairing sourceS is an important SIP element. We suggestthatthat each state clearly identify and apportionby State, or other geographic means, the significant levels ofpollutants contributed to each Class I areaby source. Developing this information togetherwith neighboring States and Tribes will facilitate consistency. Discussions ofchanging source area contributions at boththe base- and future-year levels will help demonstrate SIP progress. Considerthe benefits of presenting this information inthe form oftransported mass by pollutant orthrough individually calculated visibility impairment measures. Using a percentage or "Top 10" ranking for current contributions by geographic areamayor 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 meetthese 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 thatthis uniform rate ofprogress assessment is useful in determining the geographic and economic extent a State can considerwhen developing the LTS associated withthe reasonable progress goals.
In general, we will be looking atthe degree to which the LTS is supported by RPO technical work and at the level ofconsistency among the contributing States. For Class I areas where your State is setting a 2018 reasonable progress goal ofequal or less impairment comparedto the uniform rate ofprogress, ourreview 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 ofprogress, consider presenting information on a component basis. Components could consist ofemission 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 uniformprogress 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 ofprogress was made in the focus area, verses other less controllable factors.

2Wildland Fire Your state has considerable flexibility as it addresses all anthropogenic sources of visibility impairment, including fire. The RHRrequires consideration ofsmoke managementtechniques for agricultural and forestry managementpractices inthe development ofthe LTS part ofthe SIP. On a short-term basis,fire, both natural and anthropogenic, has the potential to cause significantvisibility reduction in Class I areas. Ifanthropogenic fire contributes to the index usedto 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 aprojection for changes to the future inventory. Ifyour state has a SMP, is it abasic smoke managementprogram 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 eithernatural 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 inthe 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 towardregionally consistent approaches to address visibility impairmentthroughout the 

### SIP development process. There may be circumstances when different methods were used or impairment assessments reached different conclusions. The FLMs understandthat each State knows what emission control methods or air quality management strategies work best for its areas. Each State may wishto 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 ofStates identifies and addresses similar, agreedupon goals for each Class I areawithin a common area ofinfluence. Regional consistency can also be difficultto evaluate ifneighboring SIPs (or portions of SIPs) are released for review at differenttimes. We expectthatthorough inter-State consultationprocesses will leadto consistent descriptions ofapportionment and emission control goals, thus resulting in development ofsimilarprogress goals, regardless of release dates. Verification and Contingencies Little emphasis has been placed inthe RHR on verification and even less on contingency planning. By rule, each SIP must identify the monitoring dataused to specify the original baseline and also as part ofan ongoing progress review at five-year intervals. Given the uncertain future ofany individual monitoring site, we suggestthatthe SIP address the representativeness ofboth primary and alternative data sites for each class I area.



### 3Consider not only the datanecessary to measnre progress but also how to account for and mitigate both unexpected and reasonably foreseeable emissions growth, changes to the geographic distribution ofemissions, and substantive errors thatmay be found in emission inventories or othertechnical bases ofthe SIPs, These factors, as well as other unanticipated circumstances, may adversely affectyonr 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 withthe 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 landmanagers for each ofthe 88 Forest Service Class I areas are listed in attachment2. As named inthe cover letterto this attachment, a single Forest Service air specialisthas been assigned to your state. He or she will facilitate the coordination ofcomments from multiple Forest Service FLMs if they exist in yonr state.



### 4

# I I USDA United States Departmentof Agricnltnre Forest Service IntermountainRegion 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 ofEnvironmental Quality 122 W. 25th Street Cheyenne, WY 82002

Dear Mr. Finley:
The Forest Service (FS) has reviewed the Department ofEnvironmental Quality'S (DEQ) Best Available Retro-FitTechnology (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 underthe BARTprocess may also affectthe other program elements affecting ournation's ability to improve visibility. With this broaderperspective, the FS offers the following comments on the DEQ's BART determinations. 

### Dispersion Modeling

- Ozone Concentrations:
The FS is concernedthat visibility impacts may be underestimated in the refined modeling, as causedby an under-representation ofthe ozone concentration. The ozone dataused inthe BART modeling is notbelieved to be spatially ortemporally representative ofthe ozone concentration ofaplume/pufftraveling from any ofthe BART-eligible emission sources near Green River toward the Fitzpatrick and Bridger Wilderness areas. Emissions ofair pollutants originating near Green River must pass through the atmosphere nearthe Jonah and Wamsutter oil and gas fields as they travel toward the Bridger and Fitzpatrick Wilderness areas. The ozone dataused in the modeling is from 200I through 2003. In 200I, 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 wintertime exceedance ofthe ozone standard was experienced in Sublette County. Hence, hourly ozone dataused inthe refined dispersion modeling for the BART analyses is not temporally representative. Similarly, the spatial distribution ofthe ozone monitoring sites used inthe BART modeling analysis is suspect. Recent studies ofmonitoring locations in southwestern Wyoming have certainly raised awareness ofthe complexity ofaddressing this issue. Unfortunately, the Pinedale ozone monitoring site was not operating during this study period, so a direct comparison is notpossible

..However, the areanear South Pass appears to have higher ozone

1Wyoming Oil & Gas Commission.

Caring for the Land and ServingPeople 

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

### 2

concentrations than near Pinedale. As such, the FS is concerned thatthe ozone data used in the BART modeling is not spatially representative.
The underestimation ofozone concentration affects the model-predicted haze impacts primarily for nitrates, as follows. Ozone is the primary source ofhydroxyl radicals (01-1), which playa key role in the formation ofammonium sulfate [(NH4)2S04] and ammonium nitrate (NI-I4N03) inthe CALPUFF model. Ozone serves as the primary source ofhydroxyl radicals, which react with N02to form nitric acid. The nitric acid reacts with ammoniato form ammonium nitrate. Figure 1 below illustrates the effect ofozone concentration onthe formation ofnitric acid (RN03), which is also affectedby PG stability class and N02 concentration. Underestimating the ozone concentration by 20 ppb (e.g., 40 ppb instead of60 ppb), may result in a 50 percent underestimation inthe conversion rate ofN02 to nitric acid, and effectively reduce the modelpredicted haze by halffor a given hour. Figure 

### 1. Effect ofOzone 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 datato ensure an appropriately representative value is used, andrerun the BART dispersion modeling analysis.
Natural Background Concentration:
The DEQ states that "Species concentrations corresponding to the 20 percentbest days were calculated for each Class I areaby scaling back the annual average concentrations given in Table 

### 2-1 ofthe EPA document Guidancefor EstimatingNatural Visibility Conditions Under the RegionalHaze Rule." Additional information is needed to understand and evaluate the use of scaling factors as applied to the alU1ual average concentrations for calculating background

### OllarMr. Finley 

### 3

concentrations for the 20 percentbest days. As this information is used inthe quantification of changein light extinction, which is subsequently comparedwiththresholds ofacceptance, a thorough understanding ofthis approach is needed for concurrence. 

### USDA Forest Service Comments on BART Determination for FMC Granger
The FS understands thattwo 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 determinationthatthese BART-eligible units are not subjectto BART at this time. 

### USDA Forest Service Comments on BART Determination for FMC Westvaco Facility AP-6045
The FS has reviewedthe 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 notto be subjectto BART based upon the results of refined dispersion modeling. The remaining two units NS-IA andNS-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 lowNOx burners and OFA for NOx is sufficient to bring the model-predicted 98th 

### percentile impactbelow the 0.5**~dv** 

### threshold. As such, the OEQ recommends thatno 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 considerthe cumulative impacts ofseveral BART-eligible sources in the Green River area. Considerthe following discussion contained in the preamble to the Regional Haze Rule pp 39120-39121.
"In a regulatory context, we believe thata State's decision as to an appropriate thresholdfor contribution coulddependupon the numberof sources affecting a class Iarea, To illustrate, 

## if there were only one emissions source affecting visibility in a class Iarea, thatsource couldhave a deciview impact onlyslightly below theperceptibility thresholdwith outcontributing to noticeable impairment. However, 

## if there were 1000 sources each changing visibility by O.I deciviews, the total impactwouldbe a 10 deciview change in visibility. In this hypothetical example, all 100 sources wouldbe contributing in equal amounts to substantialvisibility impairment. " 

### Currently, there are two BART-eligible sources atthe FMC Granger facility, three BARTeligible sources atthe FMC Westvaco facility, and two BART-eligible sources located atDllar 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 tojustbelow 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 atthis time will help the DEQ move closertoward its reasonable progress goals. Hence, whether these controls are implemented as part ofBART orunder 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 ofgas routed exhaustthrough 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 ofperforated trays; use oforganic acid additives; improve or upgrade scrubber auxiliary system equipment; and redesign spray header or nozzle configuration. Each ofthese upgrade options shouldbe considered inthe BART analyses. Analysis ofControl Technologies in the Visibility Modeling: 

### In evaluating the effectiveness ofthe various control options in reducing haze, itwould 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 oflow NOx burners with enhanced OFA meeting NOx emission limits of0,35 Ib/MMBtu (30-day rolling average), represents BART for each ofthe coal-fired boilers. The DEQ states thatthis determination is based on the results ofthe visibility analysis, which show that FMC's proposed BART control option results in an average reduction of0.3 L\.dv in the 98th percent result at BridgerWilderness Area as compared to the baseline condition for each unit, and areduction of0.2 L\.dv in the 98th percent result at Fitzpatrick Wilderness Area comparedto baseline conditions. The 98th percentile values for bothunits 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 inthe preamble 

### to its BART Guideline2that "Even though visibility improvementfrom an individual source may notbe perceptible, it should still be considered in setting BART because the contributionto haze maybe significantrelative to other source contributions inthe Class I areas." Giventhe 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 emissionunits at General Chemical Green River Works. We understandthe two units are tangentially fired boilers using in-line pulverizers to burn low sulfur subbituminous coal, which supply power andprocess steam to the mining and ore processing operations. Boiler C has a firing rate of534 MMBtu/hr and BoilerD has a firing rate of880 MMBtu/hr. Eachboileris currently equipped with ahot-side ESP to control particulates, overfire air and low excess air used to reduce NOx, and no add-on controls for S02. Our comments arepresentedbelow. Dispersion Modeling: 

### Please refer to ourprevious comments on ozone concentrations and use ofscaling factors for determination ofbackground concentrations. Effectiveness ofControl Technologies: NOx 

### In its preamble to its BART Guidelines, EPA states, "Many control techniques

...canperform at a wide range oflevels

.. .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 ofNOx 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. LowerNOx emissionrates 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 (equivalentto 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 of0.136 Ibs/MMBtu. SNCR alone can achieve between 30-50 percentreductions inNOx4

. 

### SCR can achieve up to 90 percentreductions.

2 Federal RegisterNo!. 70 No. 128/Wednesday, July 6, 2005. Page 39129 3 Aistom TFS 2000R Low NOx Control Systerm 4U.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 thanbest achievable control effectiveness results in lower model-predicted reductions in haze, and therefore potentially affects the determination ofBART.
Costs:
The costs for applying each ofthese control technologies is higherthan typical costranges. For example, ultra lowNOx burners with advanced over-fire air, tangentially-fired boilers cost between $300 and $1200 per ton, whereas the costs are estimated at $1332 perton for Boiler C and $1433 for BoilerD. Typical SNCR costs are $500

- $1500 per tonG, whereas the proposed costs are estimated at $2712 perton for Boiler C and $2025 per ton for Boiler D.
Western Backstop Sulfur Dioxide Trading Program:
The DEQ has stated that "General Chemical will notbe required to meet either proposed emission limit under BART. Instead, General Chemical will be required to participate inthe 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), itis shown that greater reasonable progress will be achieved for these additional Class I areas (e.g., Fitzpatrick and BridgerWilderness Areas) than would be achieved through the application ofsource-specific BART emission limitations under 51.308 (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. Shouldyou 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 JeffA Sorkin RickGraw ScottA 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 ofEnvironmental Quality 122 West 25th St. Cheyenne, WY 82002
Dear Mr. Finley: The Forest Service (FS) has completed its review ofthe best available retrofittechnology (BART) materials for the BART-subject electric generating units (EGUs),Jim Bridger and Naughton powerplants posted onthe Wyoming Department ofEnvironmental 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 akey part ofthe regional haze planthe State ofWyoming is preparing. This plan will demonstrate how Wyoming will make reasonable progress toward meeting the national goal ofpreventing any future, and remedying any existing, impairment of visibility in mandatory Class I areas. The regulations describing whatthese 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, FlatTops, 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 ofhow it addressedthe FLM comments ifthey are received in the specifiedtimeframe.
As you know, the BART determination must considerthe "best system ofcontinuous emissions control technology" taldng into accountthe following factors: "the technology available, the costs of compliance, the energy andnon air quality environmental impacts of compliance, any pollution control equipment in use atthe source, the remaining useful life of the source, andthe degree of improvement in visibility," 40 CFR Section 51.308(e)(I)(ii)(A).
Our review ofthe five statutory factors leads us to the conclusionthat selective catalytic reduction (SCR) shouldbe BART for nitrogen oxides (NOx) for all units atboththe Jim Bridger and Naughtonpower plants. We applaud the State ofWyoming for proposing to install SCR at the 4 units atthe Jim Bridger EGU. The FS believes the installationtimeframe for SCR should be within the 2015-2016 timeframe for all four units atthe 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 thatthe installation ofwet FGD equipment for the Naughton Power Plant Units 1-3 should be BART. 2

The United States Forest Service compliments you on yourhard 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 ofnatural 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. Ifyou have questions or comments, please contact Jeff Sorkin, at (303)-275-5759.
Sincerely,

/s/RickD. Cables RICK D. CABLES Regional Forester Rocky Mountain Region
Enclosures

cc: JeffA 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 RegionUnited 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 powerplant; 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 ofthe Extent ofVisibility Impacts: PacifiCorp modeled visibility improvements from proposed BART and reasonable progress controls. The FS feels it is importantto 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 ofeach BART alternative should be divided by the sum ofthe deciview improvement at all impacted Class I areas to determine the costper deciview. This may result in acceptance ofa previously discarded control alternative due to the showing ofareasonable cost ofvisibility 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 areasjustbeyond 3001an, ifany modeling already exists showing visibility improvementbenefits greater than 0.5dvbeyond 300km, the FS requests that informationbe included as well.
The State ofWyoming has determined thatthe Savage Run Wilderness Areawill 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 BARTreview. Pages ES-5 and 5-10 ofthe PacifiCorp BART Analysis discuss "Just-noticeable difference in atmospheric haze" indicating thatminimal, ifany, observable visibility improvements atthe Class I areas wouldbe expected under any ofthe control scenarios. 

### It is incorrectto dismiss a control strategy onthe basis thatthe resulting improvement is notperceptible or significant. EPA states inthe preamble to its BART Guidelines:
"Even though the visibility improvement/rom an individualsource may notbe perceptible, 

### itshouldstill be considered in settingBARTbecause the contribution to haze may be significantrelative to othersource contributions in the Class Iareas, Thus, we disagree thatthe degree 

## 0/ impairmentshouldbe contingent uponperceptibility, Failing to consider less-than-perceptible contributions to visibility impairmentwouldignore the CAA's intent to have BARTrequirements apply to sources that contribute to, as wellas cause, such impairment.,,3

### Five Factor Analysis for BART Selection:
In the BART determination the State ofWyoming discusses the applicability ofpresumptive BARTto units at the Jim Bridger and Naughton power plants. EPA's view ofpresumptive limits for S02 and NOx for EGUs are that they are 

### "highly costeffective." EPA goes on to say: 

### "States, as ageneral maUer, mustrequire owners andoperators of greater than 750MW powerplants to meetthese BARTemission limits. We are establishing these requirements basedon the consideration of certainfactors discussedbelow. Although we believe that these requirements are extremely likely to be appropriatefor allgreater than 750MW powerplants subjectto BART, aState may establish differentrequirements 

## if the State can demonstrate thatan alternative determination isjustifiedbasedon a consideration of thefive 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 thatthe analysis of coal composition is not only flawed in its conclusions, more principally, it does not meetthe requirement for a demonstration ofwhy presumptive limits cannot be reached. 

### NOx Controls:
The FS sees the informationpresented as supporting SCR as BART for all units atboth Jim Bridger and Naughton powerplants.
The State ofWyoming lists the following reasons for not installing SCR as BART on the 4 units atthe Jim Bridger power plant and units 1 and 2 at the Naughton power plant: 

### I) "The costof compliancefor installingSCR on each unit is significantly higherthan LNB with separatedOFA." 2) "Combustion control usingLNB with separatedOF A does not require non-air quality environmentalmitigationfor the use of chemicalreagents (i.e., ammonia or urea) andthere is aminimalenergy impact." However, the FS believes SCRis BART for all units atbothfacilities. The State ofWyoming appears to concur with this finding because, in the determination, the State says 

### "The cost effectiveness andincremental costeffectiveness of thefourproposedBARTtechnologiesfor NOx are allreasonable". In addition, FS is confused as to why Wyoming determines SCR as BART at unit 3 atthe Naughton Power Plant at $283

### Olton but for unclear reasons not atthe other six units with costs from $2258

- 

### 2848/ton.
The FS would like to point outthat SCR is a mature technology. We are unaware ofany 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.

### Forthe Jim BridgerPower Plantunits, the State ofWyoming indicates:
"The cumulative 3-year averagedvisibility improvementfrom Post-ControlScenarioA across the three Class Iareas achievedwith Post-ControlScenario B was 0.627LJdvper unit from Units 

### 1-3 and0.635LJdvfrom Unit 4."


### This statement makes the case that SCR would result in a significantimprovement in visibility, Each unit by itselfimproves visibility by an amount thatresults in "contribution" to visibility impairmentLe, it exceeds 0.5 dv, The total benefit ofSCR onthe four units (-2,5dv) easily exceeds the threshold for "causing" visibility impairment, 1.0dv, Similarly, for the Naughton Power Plant units, the State ofWyoming indicates:
"The cumulative 3-year averaged98thpercentile visibility improvement from PostControl ScenarioA across both Class 

### 1areas achievedwith Post-ControlScenario B was 0.405 LJdvfrom Unit 

### 1 and0.506LJdvfrom Unit 2," 

### Again, the FS sees this fact as making the case thatthis is a significantimprovement invisibility, Eachunitby itselfimproves visibilityby an amountthatresults in, or approaches, a "contribution" to visibility impairment. The total impact ofSCR onthe two units approaches the threshold for "causing" impairment. Regarding SCR inthe BART phase ofthe analysis, Table 7 ofthe Wyoming BART Application Analysis shows aremoval efficiency of84.4 percent for 

### LNB/OFAISCRto reach 0,07 Ib/MMBtu, PacifiCorp and Wyoming have underestimatedthe ability ofmodern NOx 

### control systems. SCR has been retrofittedto many easternpulverized 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 withhigher fuel-bound nitrogenthan thatburned at the Jim BridgerPowerPlant. Because "fuelnitrogen can account for up to 80percent of total NOxfrom coal combustion" 

### it should be easier for PacifiCorp to achieve lowerNOx

### emissions than an EOU burning coal with higher fuel-bound nitrogen, IfSCR 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 thatthe already-permitted installation ofwetFOD equipmentfor the Jim BridgerPower Plant Units 1-4 should be considered BART. Similarly, the FS believes that the

### installation ofwet FGD equipment for the Naughton PowerPlantUnits 1-3 should be considered BART. There appears to be an error in the analysis for unit 3 atNaughton. The performance ofthe wet FGD was statedto be 0.10 IblMMBtu (Table 18) butthe 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 correctvalue.
The FS understands the role ofsection 309 in exempting the State ofWyoming from BART and reasonable progress controls for S02 based onthe demonstration in WRAP Technical Support Document! thatthe S02 emissions reductions benefits under section 309 exceed those thatwould have resulted from BART. Further we understand thatthe State ofWyoming has met ittargets underthe 309 program. The FS would like to know ifthe controls in place atthe Naughton and Jim BridgerPower Plants are at least equivalentto the control scenario used inthe demonstration report. In otherwords, are the existing S02 controls actually as needed to accomplishthe "better than BART" demonstration?
The FS also notes thatthe 309 program sunsets in 2018, and that additional S02 controls may be appropriate for reasonable progress atthat 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 SupportDocumentfor the Requirements of §309 of the RegionalHaze Rule, 5/2008. 

### 2. 40 CFR Part 51, Appendix Y. U.S. Environmental Protection Agency, "Guidelines for BART Detenninations Underthe Regional I-laze Rule.", July 6, 2005, See FRVol 70, No 128, page 39161. 3. See 40 CFRPart 51, Appendix Y. The U.S. Environmental ProtectionAgency finalized it's BART Guidelines on June 15,2005, andpublishedthe preamble and final rule text in the Federal Register on July 6, 2005. The rulemaking action added Appendix Yto 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 ofEnvironmental 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 ImplementationPlan (SIP). The FS concurs and supports the review and findings ofthe US Department ofInterior, 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 ofpreventing any future, and remedying any existing, impairment ofvisibility in mandatory Class I areas. The regulations describing whatthese plans should contain are found at40 CFR 51.300 through 309. As the Federal Land Manager (FLM) for the NorthAbsaroka, Washakie, Teton, Fitzpatrick, Bridger, Savage Run, Mount Zirkel, Rawah, FlatTops, and Eagles Nest Class I Wildernesses, the FS is very interested inthe Wyoming Regional Haze Plan. As you are aware, the regional haze regulations at 40 CFR 51.308(i) require consultation betweenthe FLMs and the State. Specifically:
The State mustprovide the FederalLandManager with an opportunity for consultation, Inperson andat least 60 dayspriorto holdinganypublichearing on an Implementationplan (orplan revision) for regionalhaze requiredby this subpart. This consultation must include the opportunity for the affectedFederalLandManagers to discuss their: (I) Assessmentof Impairmentof visibility in any mandatory Class {Federalarea; and (Ii) Recommendations on the development of the reasonableprogressgoalandon the development andImplementation of strategies to address visibility impairment. 

### Detailed comments onthe SIP materials and related BestAvailable Retrofit Technology (BART) materials are included with this letter, specifically, I) FS Comments onthe Regional Haze SIP, 2) FS Comments onNon-EGU BART Sources, 3) FS Comments on EGU BART Sources, 4) US EPA Comments on Reasonable Progress (for reference).
The FS compliments you on yourhard 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 CleanAir Act's goal ofnatural 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. Ifyou have questions or comments, please contactJeffSorkin ofour Rocky Mountain Region, at (303) 275-5759. Sincerely, 

### /s/ Antoine 

### 1. Dixon for RICK D. CABLES Regional Forester, Rocky Mountain Region

cc: JeffA Sorkin Randy Karstaedt Susan A Stewart Terry Svalberg Scott A Copeland Ann Acheson 

### /s/Jerome Perezfor HARV FORSGREN Regional Forester, Intermountain RegionU.S. Forest Service Detailed Comments: Wyoming RH SIP October 7, 2009
General comment: 

### The Wyoming 309(g) RH SIP is adetailed document which addresses all of the requested elements outlined inthe 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 ofWyoming has determinedthat it should be managed as a Class I area. The State has officially declared Savage Run aWyoming Class I area. General comment: 

### Multiple air quality modeling exercises (PRB Coal Review, Pinedale Anticline, and others) identifypotential 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 benefitWyoming in designing Reasonable Progress (RP) strategies. Chapters 4 and 5: 

### Tables 4.2-1 and 4.3-1 showprojected 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 onthe best and worst20% days at all Wyoming Class I areas. The PSAT model also shows increases in NOx

### impacts on

### the worst 20% days at YELL and BRID, andbest20% days at BRID. The FS understands thatthe PSAT modeling was done early in the RH SIP process and relies on emissions inventories that do not include all emissions reductions soughtby Wyoming. Nevertheless, Wyoming is required to demonstrate thatthe State is obtaining 

### "its share o/the emission reductions neededto meetthe progress goal/or the area", per 40 CFR 51.308 (d) 3. While the FS acknowledges that Wyoming may be meeting this requirementthrough 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 ofpotential 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 inthe SO, backstop trading program, andthe 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 commentperiod. FS intendsthat 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 requirementto perform reasonable progress analyses for S02 at Class I areas that are notpart ofthe 16 Colorado Plateau Class I areas. Wyoming has not demonstrated that its plan represents greater visibility improvementthan is expected to result from implementation ofother requirements ofthe CAA.

40 CFR 51.308 (d) 1

... (vi) The State may notadopt a reasonableprogress goal that represents less visibility improvement than is expectedto resultfrom implementation of other requirements of the CAA during the applicabie planningperiod. For example, Table 4.3-1 lists roughly 24,000 tons peryear (TPY) ofincrease inNOxemissions from Area and Oil & Gas sources, and roughly 7,000 TPY ofNOxreductions from BARTpoint sources. (It is noted thatpoint source BARTNOxreductions may actually be much larger.) The additional reductions ofroughly 50,000 TPY come from mobile source rules which wouldbe counted as 

### "other requirements a/the CAA". Not counting the mobile NOxreductions, Wyoming has chosen a reasonable progress goal thatmay be a net addition ofNOx, and may represent 

### "less visibility improvement

... " depending onthe locations ofnew sources and locations ofthe "reduced" sources relative to the Class I Areas.
The use ofa Q/d screening tool for evaluating reasonable progress controls seems appropriate for large stationary sources. FS recommends the SIP include a list ofall sources considered by Wyoming and the corresponding Q/d ratios (notjustthose with Q/d>10).
Fromthe 309 (g) Technical Support Document onthe Wyoming DEQ website, this table lists sources with Q/d >1

### O. Please addto this table the identification ofwhich sources were controlled, by whattechnologies, and whether under BART or Reasonable Progress.PoInt Sources With OlD GreaterThan 10

PlilntName MOUNTAIN CEMENT CO**PACIFICORP~WiODAK** (SubJectto BARn PACIFICORP**~DAVE** JOHNSTON PAGIFICORP _DAVE JOHNSTON PAGIFICORP_DAVE JOHNSTON (SubJeI;tto BARn PACIFICORP_DAVE JOHNSTON (SubJoctto BART) PACIFICORP_NAUGHTON POv'llE:R PLANT (SUbject to BART) PACIFICORP_NAUGHTON POWER PLANT (Subjectto BART) PACIFICORP_NAUGHTON POWER PLANT (SubJl'oCtto 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-ctto BART) FMC CORP**~GREEN** RIVER PLANT_SODIUM PROD ($llbjactto BARTj PACIFICORP_JIM BRIDGER (Subject 10 aAIU) PACIFICORP_JIM BRIDGER (Subject to BART) PACIFICORP_JIM BRIDQER(Stlbjectto BART) PACIFICORP_JIM BRIDGER (Subjectto 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 Distanceto 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 BridgerWilderness rN'f) 4731.26053 75 63.06374 BridgerWilderness rN'f) 3798.40423 75 50.64539 BridgerWildemess (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 BridgerWilderness ryvY) 1077970520 113 95.39562 Bridger\lVildernesa ry.N) 9853.98238 113 87,20338 BridgerWilderness (WY) 10077.32077 113 89.17963 BridgerWilderness (Wi) 9889.16059 113 87.61470 BridgerWilderness (WY)

When citing cost effectiveness value, such as inregard 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 directrelevance 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 appearto be relatedto the four factors in 40 CFR 51.308(d)(I)(i)(A), which are required to be consideredin making the determination ofRP goals below the URP.
40 CFR 51.308 (d) (1) (ii) "the State mustdemonstrate, basedon thefactors in paragraph (d)(l)(t)(A) of this section, that the rate of progressfor the implementationplan to attain natural conditions by 2064 is notreasonable; andthat theprogress goal adoptedby the State Is reasonable."
The FS understands that Wyoming is waiting for rulemaking "to obtain authority to further evaluate non-BART sources", and thatthe expectation is thatthe State will have this authority in 2013. In the absence ofthe four-factor demonstrationreferred to above, the FS concludes that Wyoming's proposed RP goals are not sufficientlyjustified.
Section 7.6

- Additional Items:
1. Neff, et al. 2008, suggestthat roughly 75% ofwindblown 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 itis true that Western Class I areas are cleanerthan 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 importantto 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 adequatejob ofdemonstrating impacts from Wyoming emissions on surrounding States' Class I areas, the documentation ofthe projected impacts from Wyoming emissions on surrounding States' Class I areas inthe future is only available inthe 309 (g) Technical Support Document. The FS understands that these projections may be incorrect due to outdated emissions inventories; however, a projected increase in Wyoming's impacts at other States' Class I areas is a salientpointthat deserves mention in the SIP itself.
The FS believes thatthe 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% of14% is a "small portion", that is on average 

### over many days. The maximum daily contributions could be muchhigher. In other words, impacts from Wyoming could be very large on an episodic basis. Further, projections offuture increases in Wyoming NO, impacts, (as shownbelow for best days atMount Zirkel Wilderness) could significantly increase Wyoming's share ofimpacts even as surrounding States try to meettheir reasonable progress goals.Wyoming**Nltl'1lt~** Contribution to Mount ZI**rk~1**

### P.130 indicates: "By 2018, NOxemissionsfrom Wyoming areprojectedby the WRAP to decrease by 

### 39,861 tons, which willhelp reduce Wyoming's impact to out of state 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 Bridgerpower 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 supposedto beginproducing tier 4!transitional heavy-duty engines inthe period 20

### II to 2014 and tier 4/final engines beginning in 2015. These changes inthe manufacture ofheavy-duty engines will occurwell withinthe planning period and shouldbe acknowledged inthe SIP. Section 8.2.1.7.2 discusses the EPA's natural events policy of1996. As of2007, this policyhas been superseded by an exceptional events rule under 40 CFR 50.13 (40 CFR 51 was also affectedby 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 atThunder BasinNational Grasslands and Cloud Peak Wilderness. FS finds this informationuseful 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 appliedto the cementkiln.
Table 7.3.4-2 Column 3

- Potential Emission Reductions (1000 tons! yr). Should be TPY.
P167

. "In spite ofthe large number ofgrowing uncontrollable sources inthe WRAP region, however, Wyoming does see a netvisibility improvement at the Wyoming Class I areas through 2018." Should read "uncontrollable sources impacting the WRAP region

..."? Section 7.3.5 Please correctthe typo onthe acronym for air-fuel ratio controls (AFRC) inthe last sentence onpage 122.Chapter 8, p. 133 

### In the last sentence under the Bridger-Fitzpatricknitrate section on page 133, please revise the phrase "ofat 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 ofAir Quality Department'ofEnvironmental Quality 122 W. 25th 

### St, ' Cheyenne, WY 82002 Re: Preliminary Comments on WRAP's SourceSpecific Four-FactorAnalyses for Reasonable Progress in Wyoming DearMr. Finley: Please find enclosed EPA's preliminary comments onthe draft 

### Supplementary Informationfor Four-FactorAnalyses forSelectedIndividualFacilities in Wyoming, dated May 6, 2009. In addition, some ofthesepreliminary comments pertainto theMay 4, 2009, draft 

### SupplementaryIriformationfor FourFactorAnalyses 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 understandthat you intendto use these reports to supplementthe State's Reasonable Progress analysis forthe Wyoming Regional Haze SIP, Please note these comments are highly preliminary, Given the nature ofEC/R's fourfactor analyses and our uncertainty regarding theirfuture use, we did not attempt to identify every concern. Also, as you know, we will onlyreach afinal conclusion regarding the adequacy of Wyoming'sReasonable Progress analysis and Regional Haze SIP when we act on Wyoming's Regional Haze SIP revision through notice and commentrulemaking, Thank you foryour considerations ofourconcerns, Ifyou have any questions, you may contact me at (303) 312·6434, oryour staffmay contact Amy Plattat (303) 312·6449, Sincerely,

.

# 4/C,c:f:~~**~Videtich,** Director ' Air Pro&Tam EnclosureENCLOSURE
EPA Region 8 Preliminary Comments on the May 6, 2069, Draft

. Supplementary Informationfor Four-FactorAnalyses fot SelectedIndividualFacilities in Wyoming

• Region 8 is concerned that Wyoming's draft analysis does not consider any additional S02 measures necessary for demonstratingReasonable 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 RegionalHaze 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 thathave 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. Ifa Transport Region State submits an implementationplan which is approved by EPA as meetingthe requirements ofthis section, itwill be deemed to comply with the requirements for 

### RP for the period from approval ofthe plan to 2018,

. (I) A demonstration ofexpected visibility conditions for the mostimpaired and leastimpaired days at the additional mandatory Class IFederal area(s) based on emissions projections from the long-term strategies in the implementationplan, 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 

## rareas. These provisions must comply with the provisions of51.3OS(d)(I) through (4). (i) In developing LTSs pursuantto 51.308(d)(3), the State may build upon the strategies implemented underparagraph (di ofthis section, and take full creditfor the visibility improvement achieved through these strategies.

1 Paragraph d ofthis section includes requirements for the backstop trading program (BSTP), 1The 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 implementedunderthe backstop trading program (BSTP) in its RP analysis. However, the state must provide a demonstration in its SIP of howthe 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

### SupplementaryIn/ormation/orFour FactorAnalyses by WRAP States ("GeneralReport"). How did Wyoming selectthe sources to be analyzed? Howwere certain emission units selected? What sources and source categories were found to significantly impactvisibility? You will need to discuss your selection criteria in the Reasonable Progress section ofthe SIP and explain why the sources you select are the appropriate sources to address under Reasonable Progress/Long-term Strategy requirements. Ifthe State does not address certaln sources or source categories, or elects to defer some reductions to a future planning period, the State mustprovide adequate justification and documentation for doing so. 

### In addition, without knowing Wyoming's uniformrate .ofprogress levels and how the EC/Rreports will be used in Wyoming's SIP effort, it is difficult to fully reviewthe 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 criteriawere used to cutoff 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, secondparagraph: 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 shouldread, "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 onthe waste stream, waterconsumption" 

### and/or wastewater disposal. However, the remaillingfourtypes ofiInpacts listed donot fall into these categories ofhnpacts, 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/MMBtuvaluefor the DaveJomston UJ1its, because control efficiencies and Costs dependupon existingIblMMBtu emissionrates.

• Page 3-2 (firstparagraph): It 

### is ourunderstanding that costinformation is already available for larger sized boilers so there s!houldbe'no need to extrapolate the capital cost data. In addition, the annual capital cost should be calculatedusing a, Capital Recovery Factor (CRF), which is added to, not multipliedby, the O&M costs. '

• Page 3-2, lastparagraph, and Page 4-4, secondparagraph: Thesetimelines for compliance for the boilers seemto be overestimated and/or don'taccount for steps that could be completed inparallel. Similarly, anestimated seven years to control the Mountain Cement Company's Laramie CementPlantkiln is notrealistic, and should be shortened, as akiln is nowhere nearas complex as apowerplant. 'In addition, thetime, necessary for compliance should not includetime to develop regulations. Ifnew regulations are necessary, suchregulationS should be submitted withthe forthcoming SIP. The statementthattwo years maybe**need~d** 

### to develop the rules to implementthe strategy implies thatthe State lacks authority to develop and supmit a SIPto address Long-term Strategy and Reasonable Progress requirements, includingrelevantreasonable progress measures.

• Page 3-2 (Table 3-2): The estimated control efficiency ranges do not appearto be reasonable. It 

### would better serve thereaderto provide abest estimate ofcontrol efficiency as adistinct numberrather than'arange (while acknowledging thatthere is a range ofuncertainty aroundthatestimate inthe text or afootnote). ForNO" we suggest using 40% for LNB, 60% for LNB with OFA, 50% for SNCR, and 90% for SCR. It 

### should be notedthatNO, controls can illso beusedincombination, 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): ECIRhas calculatedthe emissionreduction numbers using the upperend ofthe control efficiencyrange,.whichcould be misleading. Again, acentral estimate (with upperand lowerbounds 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 thatthese controls can also be used incombination, andthe reductions that resultfrom using the control technologies in combination should also be evaluated. For example, you could instilll LNB, OFA, SNCR, and SCRtogether (in'series), which mightlowerthe overall $/ton numbers.

3

### • Page 3-3, second paragraph: 

### In the first sentence, Wyoming should add SCR after "SNCR," because bothcontrol options use compressors and'steamto inject ammoniainto the flue gas. In the second sentence inthis paragraph, the report states, "Installationof SCR on an industrial boileris not expected to increase fuel consumption." However, this may not necessarily betrue, due to the fact thatthe extentthatpoweris used (i.

### e. additional fan capacity to blowflue gas throughthe SCRcatalystbed), and that when poweris replaced by increased boilercapacity, additional coal would be burned. EPA recommends modifying the statement, orremoving it altogether. 

### In addition, it should be noted that catalysts are commonlyregenerated not only to save cost, but also to eliminate the waste stream associated with catalyst disposal, which this report should acknowledge.

• Page 4-1 (fourthparagraph): Coke should be addedto the list offuels that may be used in cementkilns.

• Page 4-3, lasttwo paragraphs: Thereportindic\ltes that SCRreduces NO, emissions from exhaust gases by converting NO, to nitrate. However, SCRdoes notconvertNO, to nitrate; itreduces NO. to nitrogen gas (N2).



### • Page 4-5, first full sentence: The.report states, "There is also the additional burden of gettingrid offouled ordeactivated catalystfrom the system

- often the PM control device in the form ofafabric filter orelectrostatic precipitatorcan achieve this goal." However, in EPA's experience, one would not getrid ofacatalystwith aPM control device. As noted above, catalysts are commonly regeneratedto not only save cost, but also to elhninate awaste stream, which this report should acknowledge.

• Page 4-5, section4.4: The discussion onthe remaining useful life indicates thatthe age ofthe cementkilns was notavailable to WRAP's contractor. This information should be obtained and included inthe 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 therange of80-90%, 

### 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 lowNO, burners (LNB) presented in this table seems too high. We usually expect numbers between $500 

### and $1,000 

### perton for LNB.

4 

# @ Printedon RecycledPeperIN ftFJlI.Y REFERTO 

## United States Department ofthe ,Interior NATIONAL PARK SERVICE Air Resources Division P.O. Box 25287 Denver, CO 80225 

# 1.1::::."'**~""\** TAKE PRICE' INAMERlCA

October21,2009 N3615 (2350)

David A. Finley, Administrator Division ofAir Quality Department ofEnvironmental 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 ofthis plan. Cooperative efforts such as these ensure that, together, we will continue to make progress toward the Clean Air Act's goal ofnatural visibility conditions at all ofour most pristine National Parks and wilderness areas for future generations, This letter acknowledges that the U,S, Department ofthe 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 ofyour 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 draftimplementationplanwas well organized and addressed all the key elements outlined in our letter. We recognize Wyoming is committingto significantpoint 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 subjectto 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 ofAir 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, AirResources 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
SandraV. Silva Chief, Branch ofAir Quality U.S. Fish & Wildlife Service"

National Park**Servi~e** and U,S. Fish and Wildlife**Servi~e** Comments Wyoming DraftState 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 ofa 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 expectedreductions 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 partofits reasonable progress analyses ifadditional 

### SOl controls wouldbe warranted for Class Iareas 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 oftile 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 workclosely with the oil and gas industry to improve the emissionprojections 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% bestvisibility days atthese 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 itto 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 ofprogress 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 datain Section 4. The majority ofthe 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 estimatedinthe WRAP inventory.
Section 5: Source Apportionment and Regional HilZI: Modding
WY cites WRAP CAMx-PSAT anaIys!;s ofcontributions 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 20l8PRPa 802inventory, 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, andparticulate 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, butthe WY Class I areas 

### wiU not achieve the uniformrate ofprogress. 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 ofprogress by 2018. It is important to point this out in Section 5 even ifthere are not modeling results to demonstrate the benefits ofthese additional reductions. Section 6: BART determination
NPS previously submitted comments that SCR would be cost effective as BART for NO, emissions from additional BART-eligibleElectric 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 ofWRAP CMAQ modeling for 2018. WY should clarify that RPGs listed in Table 7.5-1 are the results ofWRAP 2018b modeling without any additional controls beyond WRAP 2018b modeling, Actual reductions may be greaterthan 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 ofthe 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 ofS02 reductions expected underthe 309 SIP. Table 4.2-1 suggests anet reduction of22,000 tons S02 from all point sources by 2018, but that figure appears to include more sources than those controlling underthe 309 SIP. Table 

### 7.2-1 is notcitedin the text ofSection 

### 7.2. WY uses Q/d:: 10as an indicator ofsources that should

### be considered underreasonableprogress for additional NO, controls. Without more specific guidance from EPA, there is precedencethat other states have used asimilar approachto 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 7or at a minimum to referthe reader to the specific section (8.3.4) where the outcome ofthe reasonable progress analyses is provided. WY asserts that unifOlID rate ofprogress will not be met because much ofthe contribution is from uncontrollable sources. We believe that WY should do more to adopt cost effective controls forreasonable progress for those pollutants whichWY can control. Section 8: Long Term Strategy WY identifies contributions to Class I areas outside WYand contributions ofneighboring 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 ofprogress oncontributions 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 ofoil 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 intheWRAP 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 askind11stry to offset emissions prior to regulatory requirements. Ozone nonattainment in the Sublette County area will require WY to develop NO, emissions reduction strategies. Emissions offsetrequirements currently inplace are a start. Given that WY lacks regulatory authority for additional controls for non-BART sources, it is importantthat 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 veryhelpful in understanding the sources ofemissions reductions.
WY's long-term strategy includes discussion ofexisting 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 offine particles, the anthropogenic contribution to dust (fine PM and course PM), and prescribed fire.
We ask that WY include in the discussion ofNew Source Review and Prevention ofSigniticant Deterioration requirements recognition of visibility improvement goals so that progress in reducing emissions from existing sources is not offsetby growth in new sources. We lookforward to continuing to work with WY to protect visibility and other air quality related values in the ClassI areas and the region.



### 5i ,) 

## 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. ofEnvironmental 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 ofproposed revisions to the Wyoming Regional Haze State Implementation Plan (SIP). Inthe past, communication between the FS and the Wyoming DEQ about regional haze SIPs has been adequate, however the FS has no records ofthe State ofWyoming contacting us aboutthis SIP revision. We askto 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 ofWyoming will make reasonable progress toward meetingthe national goal ofpreventing any future, and remedying any existing, impairment ofvisibility 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, FlatTops, 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 mustprovide the FederalLandManagerwith an opportunityfor consultation. in person andat least60 daysprior to holding anypublic hearing on an implementationplan (orplan revision)for regionalhaze requiredby this subpart. This consultation mustinclude the opportunity for the affectedFederalLandManagers to discuss their: (I)Assessmentofimpairment of visibility in any mandatory Class IFederal area; and (it) Recommendations on the developmentof the reasonableprogress goalandon the developmentandimplementation of strategies to address visibility impairment. The FS has conducted acursory review ofthe 309 and 309(g) material dated October 21, 2010. We request the full 60 days, through December 20'h, to complete amore thorough review. In the interim, we can offer the following comments atthis time regarding the 309(g) material:
I. In section 8.3.5, Wyoming indicates that the DEQ can't complete evaluation ofoil and gas contributions withoutthe WRAP Phase III report. The FS understands thatthe Phase III work is in progress for the Wind River, Upper Green River, and PowderRiver 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 thatthe efforts be expanded to include all potential visibilityimpairing oil and gas related emissions.
2. Figure 8.3.6-7 does not appearto reflect the changes in BART compliance dates. The FS compliments you on your hard work and dedication to significant improvement in ournation'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 contactRandy 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