From: 	Chris Sarsony, HDR|e2M

To: 	Amy Hambrick, U.S. Environmental Protection Agency

Re:  	September 1, 2009 Meeting Between the U.S. EPA and Plymouth Tube
Inc. Regarding the Halogenated Solvent Cleaning Reconsideration

Date: 	September 9, 2009

On September 1, 2009, a teleconference meeting was held between the U.S.
Environmental Protection Agency (EPA) and representatives from Plymouth
Tube, Inc. - a narrow tube manufacturer.  The meeting participants are
listed below

Name	Organization

Tim Benner	EPA/ORD

Susmita Dubey	EPA/OGC

Amy Hambrick	EPA/OAQPS

Ann Johnson	EPA/OPEI

Elaine Manning	EPA/OAQPS

Dennis Pagano	EPA/OAQPS

Jim Robellard	Plymouth Tube, Inc.

Chris Sarsony	HDR|e2M Inc.

Kim Teal	EPA/OAQPS

Meeting Agenda:

1.	Introductions and Meeting Purpose

2.	Issues for Discussion

3.	Open Discussion

Meeting Summary:

Introductions and Meeting Purpose

Ms. Hambrick of the U.S. EPA began the meeting with introductions and by
stating the purpose for the meeting.  The meeting was as a follow up to
Plymouth Tube’s February 4, 2009 public comments on the October 20,
2008, Proposed Notice of Reconsideration and Request for Public Comment
for Halogenated Solvent Cleaning (73 FR 62384).  Specifically, EPA
wanted to obtain clarification and additional details regarding Plymouth
Tube’s products, manufacturing process, halogenated solvent cleaning
machines, and trichloroethylene (TCE) emission controls.

Ms. Hambrick indicated that a meeting summary would be developed for the
meeting and this summary would be made available to the public in the
docket.

Issues for Discussion

Background on Plymouth Tube’s operations at the Salisbury, Maryland
facility.

The Plymouth Tube Salisbury Division began operations in 1982.  At the
Salisbury facility Plymouth Tube manufactures stainless steel tubing for
the following markets:

Aerospace (jet engines, etc) – 30% of their sales

Commercial, including satellite components – 30% of their sales

Medical (stents, etc.) – 10% of their sales

Nuclear (submarines, power generation, etc.) – 30% of their sales.

They only make stainless steel tubing.  The tubing is made in lengths
from 10 feet to 148 feet.  The outer diameter (O.D.) of the tubing
ranges from 1/8 inch to 1 inch.  There can be a multitude of lengths and
O.D. combinations within the above ranges.

Their starting stock tube has an O.D. of 1 ¾ inch and a ¼ inch wall
thickness.  All their tubing is drawn from this starting stock.  Every
time the tube is drawn it gets longer.  They buy the starting stock by
the pound but sell the tubing they manufacture by the foot.  Drawing the
tubing from a 1 ¾ inch O.D. to a 1 inch O.D. may increase the tubing
length from about 40 feet to about 60 feet.  Drawing the tubing from a 1
¾ inch O.D. to a 1/8 inch O.D. may increase the tubing length to about
4,000 feet.

Plymouth’s non-nuclear tubing is sold in 20 foot lengths; however, the
process non-nuclear tubing is being degreased and cleaned at 60 foot
lengths.  The nuclear tubing which also has a small OD and small ID,
reaches lengths within a range of 120 to 148 feet.  This nuclear tubing
is coiled in 11 foot diameter coils, so that it can be transported
effectively and shipped all over the United States and abroad. No tube
bending is performed at their facility.

Their medical tubing is typically ¼ inch O.D. and smaller and has the
smallest O.D. and the thickest wall.  Therefore, their medical tubing
has a very small inner diameter (I.D.).  Some of their nuclear tubing
also has a very small O.D.

Was the reduction in TCE emissions from CY2003 to CY2004 the result of
installing new cooling coils on VD-1, or was this due to some other
effect?

The addition of the cooling coils on VD-1 played a big part in the
reduction of emissions in CY2004.  They had noticed that the cooling
zone temperature was steadily increasing over time.  The addition of the
cooling coils reduced the cooling zone temperature from around 55-56
degrees F to less than 50 degrees F.  Another factor affecting emissions
during CY2004 was the fact that they were manufacturing larger tubing
sizes that year.  This would have the effect of reducing TCE emissions.

If the cooling coils were effective in reducing emissions on VD-1, why
weren’t new cooling coils installed on the large cleaning machine
VD-2?

The larger cleaning machine (VD-2) has not been used in about 7 years
(since 2002).

Description of the solvent cleaning machines at Plymouth Tube’s
Salisbury, MD facility.

Cleaning Machine

Size

(L x W x D)

Solvent Capacity	Approximate Cost to Fill with TCE

VD-1	60ft  x 3ft x 15ft	6,600 gallons	$62,000

VD-2	62ft x 5ft x 15ft	12,125 gallons	$120,000

What caused TCE emissions to increase from CY2004 to CY2005?

The cooling coils added to VD-1 were efficient the first couple of
years, but then their efficiency dropped off.  Out of 8 cooling coil
passes only 6 of the cooling coil passes were working.  The cooling
coils were being damaged by the tubing loads going in and out of the
cleaning machine.  Also, starting in CY2005 the size of the tubing that
they manufactured got smaller, and thus, TCE emissions increased.

What were the TCE emissions from the Salisbury, MD facility in CY2008?

The TCE emissions from the Salisbury, MD facility in CY2008 were 37.3
tons.  All of these emissions were from VD-1.

Has Plymouth Tube explored the use of alternative solvents, such as nPB?

Plymouth Tube indicated that they conducted bench scale tests with nPB.
They use chlorinated paraffin based drawing lubricants that are cleaned
best at temperatures greater than 160 degrees F.  They found that nPB
left behind some lubricant residue that required a second cleaning.
Plymouth believes that this is a result of nPB’s boiling point at 140
degrees F as compared to TCE, which boils at 188 degrees F.  The higher
boiling temperature of the TCE helps to melt the chlorinated paraffin.
Plymouth explained that the combination of the long length and small
ID’s of their tubes will inhibit the effectiveness of nPB for removal
of the chlorinated paraffin from the middle of the tube ID’s.
Plymouth discussed that a solvent switch to nPB must require NRC
approval.

Plymouth stated that the nuclear tubes must pass several cleanliness
tests and inspections prior to shipment.  Other types of tubing also has
similar product-specific requirements regarding the type of cleaning and
product used, many of which specify TCE vapor degreasing.  Any solvent
switching would require Plymouth to conduct product tests and customer
approval.

Plymouth Tube reports their research has shown nPB also costs about
twice as much as TCE (TCE costs about $0.75/lb, whereas nPB is about
$1.42/lb).  Though cost is factor, Plymouth Tube stated the technical
feasibility issues and client requirements for TCE have been foremost in
their consideration of using nPB.

Can Plymouth Tube describe the carbon adsorption system (CAS) and its
control efficiency?

The CAS has three carbon beds containing a total of 10,800 lbs of
carbon.  When they talked about expanding their CAS system in their
comment letter, they were referring to adding a lip exhaust that would
go to the CAS.  However, the benefits of the lip exhaust would be
marginal because it would increase the flow of air across the solvent
cleaning machine.  Plymouth Tube’s support equipment supplier reported
that the addition of a lip exhaust on their degreaser would cause a
draft across the edge of the tank thus drawing the vapors up above the
cooling coils limiting their effectiveness.

Plymouth Tube will email the control efficiency data for their CAS to
EPA.  This is the estimated capture efficiency of 90% and removal
efficiency 98% of Plymouth’s carbon units

Please describe the cleaning process at Plymouth Tube’s Salisbury, MD
facility?

They load approximately 2,000 lbs of product into the machine at one
time.  The cover to the cleaning machine closes when the product is in
the machine.  The product is tipped into the vapor, then into the
liquid, and then into the vapor again.  At the end of the cleaning cycle
the product is held in the freeboard area of the cleaning machine to
allow solvent to drain back into the tank.  The cover to the cleaning
machine is then opened and the product is removed from the cleaning
machine.  The product is then placed into the draft tanks for 30
minutes.  The draft tanks pull a vacuum and route the captured air to
the CAS.  The air from the room is also routed to the CAS.

Has Plymouth Tube looked at replacing their open top vapor cleaning
machines with vacuum-to-vacuum (VTV) cleaning machines?

Plymouth Tube explored VTV technology which included requesting
estimates and proposals for installing the technology.  During this time
only one company, Tiyoda-Serec would entertain the prospect of building
a unit of the size that Plymouth would need. Tiyoda-Serec proposed
building an end loading machine with an interior space 60 feet long and
three feet in diameter.  Plymouth stated that neither this vendor, nor
any other VTV supplier ever had built a machine of this size and scale.

Plymouth Tube is challenged by the size and loading requirements of VTV
machines which would require significant modifications to the facility,
including construction of a new addition to handle the lateral movement
of the product for loading and unloading VTV machines.

Plymouth Tube further found, in consultation with Tiyoda-Serec that the
combination of machine length and diameter would expand the current
cleaning time from 45 minutes per cycle to 1 hour and 30 minutes per
cycle.  Because of the 1.5 hour cleaning cycle of the VTV machines,
Plymouth Tube would need two of these hypothetical machines to maintain
their current production levels.  Each machine was found to cost more
than one million dollars.  Plymouth feels that large scale VTV
technology is not proven.

Plymouth felt that installation of VTV machines and the redesign of
their building was economically and technically unfeasible.

Does Plymouth Tube have any pictures of the cleaning machines at their
Salisbury, MD facility that they could send to EPA?

Plymouth Tube will send photographs of their cleaning machines.

  PAGE   \* MERGEFORMAT  1


[Federal Register Volume 82, Number 37 (Monday, February 27, 2017)]
[Notices]
[Page 11910]
[FR Doc No: 2017-03767]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. ER17-992-000]

Springdale Energy, LLC; Supplemental Notice That Initial Market-
Based Rate Filing Includes Request for Blanket Section 204
Authorization

    This is a supplemental notice in the above-referenced proceeding of
Springdale Energy, LLC's application for market-based rate authority,
with an accompanying rate tariff, noting that such application includes
a request for blanket authorization, under 18 CFR part 34, of future
issuances of securities and assumptions of liability.
    Any person desiring to intervene or to protest should file with the
Federal Energy Regulatory Commission, 888 First Street NE., Washington,
DC 20426, in accordance with Rules 211 and 214 of the Commission's
Rules of Practice and Procedure (18 CFR 385.211 and 385.214). Anyone
filing a motion to intervene or protest must serve a copy of that
document on the Applicant.
    Notice is hereby given that the deadline for filing protests with
regard to the applicant's request for blanket authorization, under 18
CFR part 34, of future issuances of securities and assumptions of
liability, is March 13, 2017.
    The Commission encourages electronic submission of protests and
interventions in lieu of paper, using the FERC Online links at http://www.ferc.gov. To facilitate electronic service, persons with Internet
access who will eFile a document and/or be listed as a contact for an
intervenor must create and validate an eRegistration account using the
eRegistration link. Select the eFiling link to log on and submit the
intervention or protests.
    Persons unable to file electronically should submit an original and
5 copies of the intervention or protest to the Federal Energy
Regulatory Commission, 888 First Street NE., Washington, DC 20426.
    The filings in the above-referenced proceeding are accessible in
the Commission's eLibrary system by clicking on the appropriate link in
the above list. They are also available for electronic review in the
Commission's Public Reference Room in Washington, DC. There is an
eSubscription link on the Web site that enables subscribers to receive
email notification when a document is added to a subscribed docket(s).
For assistance with any FERC Online service, please email
<EMAIL_ADDRESS>or call<PHONE_NUMBER> (toll free). For
TTY, call<PHONE_NUMBER>.

    Dated: February 21, 2017.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
[FR Doc. 2017-03767 Filed 2-24-17; 8:45 am]
 BILLING CODE 6717-01-P


[Federal Register: March 31, 2010 (Volume 75, Number 61)]
[Notices]
[Page 16093-16094]
[DOCID:fr31mr10-55]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Project No. 12597-021; Project No. 12598-019]

Turnbull Hydro, LLC; Notice of Application Accepted for Filing,
Soliciting Comments, Motions To Intervene and Protests, and Ready for
Environmental Analysis; Soliciting Recommendations and Terms and
Conditions for the Proposed Changes to the Transmission Line Routes

March 24, 2010.
    Take notice that the following hydroelectric application has been
filed with the Commission and is available for public inspection:
    a. Type of Application: Amendment of License.
    b. Project Nos.: 12597-021 and P-12598-019.
    c. Date Filed: February 17, 2010, and supplemented March 17 and 23,
2010.
    d. Applicant: Turnbull Hydro, LLC.
    e. Name of Project: Lower and Upper Turnbull Drop, respectively.
    f. Location: The projects are located on the Spring Valley Canal in
Teton County, Montana.
    g. Filed Pursuant to: Federal Power Act, 16 U.S.C. 791a-825r.
    h. Applicant Contact: Mr. Ted Sorenson, Turnbull Hydro, LLC, 5203
South 11th East, Idaho Falls, ID 83404,<PHONE_NUMBER>.
    i. FERC Contact: Any questions regarding this notice should be
directed to Mr. Jeremy Jessup<PHONE_NUMBER> or<EMAIL_ADDRESS>    j. Deadline for filing motions to intervene and protests, comments,
recommendations, and preliminary terms and conditions (terms and
conditions for transmission line routes only), is 60 days from the
issuance of this notice; reply comments are due 105 days from the
issuance date of this notice. All documents may be filed electronically
via the Internet. See, 18 CFR 385.2001(a)(1)(iii) and the instructions
on the Commission's Web site at http://www.ferc.gov under the ``e-
Filing'' link. If unable to be filed electronically, documents may be
paper-filed. To paper-file, an original and eight copies should be
mailed to: Secretary, Federal Energy Regulatory Commission, 888 First
Street, NE., Washington, DC 20426. For more information on how to
submit these types of filings, please go to the Commissions Web site
located at http://ferc.gov.filing-comments.asp.
    Please include the project numbers (P-12597-021 and P-12598-019) on
any comments, motions, recommendations,

or preliminary terms and conditions filed.
    k. Description of Request: At the Lower Turnbull Drop Project, the
applicant proposes to (1) change the hydraulic capacity from 600 cfs to
750 cfs; (2) change the authorized installed capacity from 6,150 kW to
7,700 kW; and (3) change from two turbines to a single turbine. At the
Upper Turnbull Drop Project, the applicant proposes to (1) change the
hydraulic capacity from 600 cfs to 750 cfs; (2) change the authorized
installed capacity from 4,100 kW to 5,300 kW; and (3) change from two
turbines to a single turbine.
    Additionally, at the Lower Turnbull Drop Project, the applicant
proposes to (1) change the entire transmission line to 69 kV and
eliminate the remote electrical substation and (2) change the length
and location of the 69 kV transmission line. At the Upper Turnbull Drop
Project, the applicant proposes to (1) change the entire transmission
line to 69 kV and eliminate the remote electrical substation and (2)
change the length and location of the 69 kV transmission line. The
filing of terms and conditions (see section ``o'' below) are only being
requested by this notice for the applicant's proposal regarding changes
to the transmission line routes.
    l. Locations of the Application: A copy of the application is
available for inspection and reproduction at the Commission's Public
Reference Room, located at 888 First Street, NE., Room 2A, Washington,
DC 20426, or by calling<PHONE_NUMBER>. This filing may also be viewed
on the Commission's Web site at http://www.ferc.gov using the
``eLibrary'' link. Enter the docket number excluding the last three
digits in the docket number field to access the document. You may also
register online at http://www.ferc.gov/docs-filing/esubscription.asp to
be notified via e-mail of new filings and issuances related to this or
other pending projects. For assistance, call 1-866-208-3676 or e-mail
<EMAIL_ADDRESS>for TTY, call<PHONE_NUMBER>. A copy is
also available for inspection and reproduction at the address in item
(h) above.
    m. Individuals desiring to be included on the Commission's mailing
list should so indicate by writing to the Secretary of the Commission.
    n. Comments, Protests, or Motions to Intervene: Anyone may submit
comments, a protest, or a motion to intervene in accordance with the
requirements of Rules of Practice and Procedure, 18 CFR 385.210, .211,
.214. In determining the appropriate action to take, the Commission
will consider all protests or other comments filed, but only those who
file a motion to intervene in accordance with the Commission's Rules
may become a party to the proceeding. Any comments, protests, or
motions to intervene must be received on or before the specified
comment date for the particular application.
    o. Filing and Service of Responsive Documents: All filings must (1)
bear in all capital letters the title ``PROTEST'', ``MOTION TO
INTERVENE'', ``COMMENTS,'' ``REPLY COMMENTS,'' ``RECOMMENDATIONS,'' or
'' TERMS AND CONDITIONS'' (transmission line routes only); (2) set
forth in the heading the name of the applicant and the project numbers
of the application to which the filing responds; (3) furnish the name,
address, and telephone number of the person protesting or intervening;
and (4) otherwise comply with the requirements of 18 CFR 385.2001
through 385.2005. All comments, motions to intervene or protests must
set forth their evidentiary basis and otherwise comply with the
requirements of 18 CFR 4.34(b). All comments, motions to intervene or
protests should relate to project works which are the subject of the
license amendment. Agencies may obtain copies of the application
directly from the applicant. A copy of any protest or motion to
intervene must be served upon each representative of the applicant
specified in the particular application. If an intervener files
comments or documents with the Commission relating to the merits of an
issue that may affect the responsibilities of a particular resource
agency, they must also serve a copy of the document on that resource
agency. A copy of all other filings in reference to this application
must be accompanied by proof of service on all persons listed in the
service list prepared by the Commission in this proceeding, in
accordance with 18 CFR 4.34(b) and 385.2010.

Kimberly D. Bose,
Secretary.
[FR Doc. 2010-7144 Filed 3-30-10; 8:45 am]
BILLING CODE 6717-01-P


[Federal Register Volume 85, Number 133 (Friday, July 10, 2020)]
[Notices]
[Page 41582]
[FR Doc No: 2020-14910]

-----------------------------------------------------------------------

DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. EL20-57-000]

Cloverland Electric Cooperative v. Wisconsin Electric Power
Company; Notice of Complaint

    Take notice that on July 1, 2020, pursuant to sections 206, 306,
and 309 of the Federal Power Act, 16 U.S.C. 824e, and 825e, and Rule
206 of the Federal Energy Regulatory Commission's (Commission) Rules of
Practice and Procedure, 18 CFR 385.206, Cloverland Electric Cooperative
(Complainant) filed a formal complaint against Wisconsin Electric Power
Company (Respondent), alleging that the current 11 percent return on
equity of Wisconsin Electric Power Company is excessive and should be
reduced, all as more fully explained in the complaint.
    The Complainant certifies that copies of the complaint were served
on the contacts listed for Respondent in the Commission's list of
Corporate Officials.
    Any person desiring to intervene or to protest this filing must
file in accordance with Rules 211 and 214 of the Commission's Rules of
Practice and Procedure (18 CFR 385.211, 385.214). Protests will be
considered by the Commission in determining the appropriate action to
be taken, but will not serve to make protestants parties to the
proceeding. Any person wishing to become a party must file a notice of
intervention or motion to intervene, as appropriate. The Respondent's
answer and all interventions, or protests must be filed on or before
the comment date. The Respondent's answer, motions to intervene, and
protests must be served on the Complainants.
    The Commission strongly encourages electronic filings of comments,
protests and interventions in lieu of paper using the ``eFiling'' link
at http://www.ferc.gov. Persons unable to file electronically may mail
similar pleadings to the Federal Energy Regulatory Commission, 888
First Street NE, Washington, DC 20426. Hand delivered submissions in
docketed proceedings should be delivered to Health and Human Services,
12225 Wilkins Avenue, Rockville, Maryland 20852.
    In addition to publishing the full text of this document in the
Federal Register, the Commission provides all interested persons an
opportunity to view and/or print the contents of this document via the
internet through the Commission's Home Page (http://ferc.gov) using the
``eLibrary'' link. Enter the docket number excluding the last three
digits in the docket number field to access the document. At this time,
the Commission has suspended access to the Commission's Public
Reference Room, due to the proclamation declaring a National Emergency
concerning the Novel Coronavirus Disease (COVID-19), issued by the
President on March 13, 2020. For assistance, contact the Federal Energy
Regulatory Commission at<EMAIL_ADDRESS>or call toll-free,
(886) 208-3676 or TYY,<PHONE_NUMBER>.
    Comment Date: 5:00 p.m. Eastern Time on July 21, 2020.

    Dated: July 6, 2020.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
[FR Doc. 2020-14910 Filed 7-9-20; 8:45 am]
BILLING CODE 6717-01-P


6 347 6.8 Region 8 Nonattainment Areas 6.8.1 EPA 9 Factor Analyses for Montana for the Designation of PM2.5 Nonattainment Areas Based on air quality data for 2001 2003, the PM2.5 monitor at the Libby Courthouse Annex is violating the annual PM2.5 standard. EPA utilized the 9 factors identified in the April 1, 2003 " Designations for the Fine Particle National Ambient Air Quality Standards" guidance to evaluate whether the surrounding rural counties around Lincoln, MT should be included as part of the nonattainment area. However, due to the topographical features and local meteorology within Lincoln County and more specifically around the Libby, Montana vicinity, several of the 9 factors were not significant for this particular nonattainment area when looking at adjacent counties to Lincoln County, MT. Lincoln County is considered a rural county, according to EPA's April 1, 2003 " Designations for the Fine Particle National Ambient Air Quality Standards" which defines a rural area as counties or areas not included in or adjacent to urban areas ( metropolitan statistical areas ( MSA). The adjacent areas to Lincoln County are the Canadian border to the North, Boundary and Bonner County, Idaho to the West, Sanders County, MT to the South, and Flathead County, MT to the East. Lincoln County contains a violating monitor located in the town of Libby. The Lincoln County PM2.5 nonattainment issue is unique in that the area of impact is localized within and around the vicinity of the town of Libby due to topographical features and meteorology in the area impacted by emissions.

Montana's recommendation identifying the PM2.5 nonattainment area included part of Lincoln County ( the town of Libby and vicinity). EPA initially responded to Montana's recommendation stating that EPA agreed with Montana's recommended nonattainment designation for Lincoln County but that EPA intended to modify Montana's recommended boundary for the nonattainment area to cover all of Lincoln County. However, based upon supplemental information provided by Montana, EPA is identifying the boundary of this PM2.5 nonattainment area to include a part of Lincoln County as described further below.

The following is a brief summary of the 9 factor criteria for the Lincoln County, MT area and surrounding counties. These analyses were based on existing available data. The counties recommended as nonattainment are in bold.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area For this factor, EPA looked at SO2, NOx, carbon and crustal PM2.5 emissions. A weighted emissions score was applied to Lincoln County and the adjacent counties reflecting the speciation profile of Lincoln County versus the adjacent counties. Counties adjacent to the Lincoln County were assigned an emission score as a way to compare the emissions from those counties against Lincoln County emissions. The following table has the SO2, NOx, carbon, and crustal PM2.5 emissions and composite emission scores. 6 348 This information is from the 2001 NEI. ( The recommended nonattainment area is in bold.)

County SO2 ( tons) NOx ( tons) Carbon ( tons) Crustal PM2.5 ( tons) Composite Emission Score Lincoln 257 3286 862 275 100 Flathead 1919 6651 1788 1904 257 Bonner 313 5324 1411 730 159.5 Boundary 114 1886 1431 760 134.4 Sanders 328 4543 605 151 88.2 Since Lincoln County is considered to be a rural county as defined in EPA's April 1, 2003 PM2.5 Designations Guidance and not a metropolitan statistical area, this factor did not play a significant role in the decision making process. Also, due to the topographical features and meteorology in Lincoln County ( see factors 6 and 7 below) and more specifically surrounding Libby, MT where the PM2.5 problem is, EPA feels the surrounding counties emissions are not impacting the PM2.5 monitor located at the Libby Courthouse Annex.

Factor 2: Air quality in potentially included versus excluded areas County PM2.5 2001 2003 design value Lincoln 16.2*

Flathead 9.1 Bonner 8.0 Boundary 8.2 Sanders 6.2 * Lincoln County PM2.5 monitor is located at the Libby Courthouse Annex, Libby, MT.

All adjacent counties to Lincoln, MT are attaining the PM2.5 standard. This factor played a significant role in the decision making process. 6 349 Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the population and population density for Lincoln County and the adjacent counties.

County 2002 Population 2002 Population Density ( pop. per square mile) Lincoln 18,665* 5**

Flathead 77,240 15 Bonner 38,205 22 Boundary 10,085 8 Sanders 10,367 4 * Town of Libby, MT population: 2,626; ** Town of Libby, MT population density: 2,020 persons/ square mile The town of Libby, where the PM2.5 problem is located has a much higher population density than the remainder of Lincoln County or any of the surrounding counties. Also, due to the commuting patterns, topographical features and meteorology in Lincoln County ( see factors 4, 6 and 7 below), EPA feels the adjacent county populations do not impact the PM2.5 monitor located at the Libby Courthouse Annex. This factor played a significant role in the decision making process.

Factor 4: Traffic and commuting patterns Commuting Information:

Lincoln County, the design value county, has a total of 6,721 commuters.  Commuters who remain in Lincoln County: 6,177 Flathead County, an adjacent county, has a total of 34,035 commuters.  Commuters from Flathead County to Lincoln County: 85  Commuters that remain in Flathead County: 32,956 Bonner County, an adjacent county, has a total of 15,570 commuters.  Commuters from Bonner County to Lincoln County: 0  Commuters that remain in Bonner County: 12,968 Boundary County, an adjacent county, has a total of 3,830 commuters.  Commuters from Boundary County to Lincoln County: 10  Commuters that remain in Boundary County: 3,310 Sanders County, an adjacent county, has a total of 3,903 commuters.  Commuters from Sanders County to Lincoln County: 12 6 350  Commuters that remain in Sanders County: 3,337 The following table has the vehicle miles traveled ( thousand miles) for Lincoln County and the adjacent counties.

County VMT Lincoln 231 Flathead 756 Bonner 442 Boundary 139 Sanders 93 Based on the analysis for this factor there are no adjacent counties impacting the PM2.5 monitor located at the Libby Courthouse Annex. This factor played a significant role in the decision making process.

Factor 5: Expected growth The following table has the population and population growth figures for Lincoln County and the adjacent counties. ( Nonattainment counties are in bold.)

County 2002 Population Population Density Area ( sq. mile) Growth ( 90 00) % Change ( 90 00)

Lincoln 18665 5 3613 1356 8 Flathead 77240 15 5099 15253 26 Bonner 38205 22 1738 10213 38 Boundary 10085 8 1269 1539 18 Sanders 10367 4 2762 1558 18 Based on the analysis for this factor, there is no significant growth, on either an absolute or a percentage basis, to indicate a contribution to the air quality in Lincoln County. This factor did not play a significant role in the decision making process.

Factor 6: Meteorology Libby Montana is located in the northwestern part of the state in a narrow north south oriented valley. The ridgetops surrounding Libby are approximately 4,000 feet higher 6 351 than the town. There are no other towns or large emissions sources immediately upwind, so transport of high background concentrations into Libby is considered unlikely. The highest PM2.5 concentrations in Libby generally occur during the months of November through February. During the summer months concentrations typically average less than half the level of the annual PM2.5 NAAQS, while winter concentrations may double the NAAQS. The much higher concentrations in winter are related to stagnant weather conditions dominated by light winds and strong temperature inversions. These meteorological conditions may trap emissions within the valley for many days. No recent meteorological data is available for Libby, however, data from Kalispell, MT show calm wind conditions occur 35 percent of the time in the winter months and only 15 percent of the time in the spring and summer. Vertical temperature soundings at Great Falls in Western MT also show a very high frequency of surface temperature inversions in the winter.

Due to the meteorology conditions in the town and surrounding vicinity of Libby and due to the topographical features within Lincoln County and more specifically around Libby ( see factor 7 below), that create stagnant weather conditions, EPA feels the adjacent counties do not impact the PM2.5 monitor located at the Libby Courthouse Annex and that the nonattainment problem is a localized PM2.5 problem.

Prevailing Wind Directions (%)

County NW SW SE NE Lincoln 14 37 22 26 Flathead 21 34 22 24 Bonner 14 42 20 24 Boundary 12 40 22 27 Sanders 26 28 24 22 This factor played a significant role in the decision making process.

Factor 7: Geography/ topography Lincoln County, MT Lincoln County has a land area of 3,675 square miles. The area of concern showing high PM2.5 concentrations is located within and around the Libby, Montana vicinity. Lincoln County has numerous geographical or topographical boundaries limiting its airshed to a very narrow valley including the surrounding vicinity of Libby. The town of Libby has a total area of 1.3 miles. As of the 2000 census, there are 2,626 people, 1,132 households, and 669 families residing in the city. The elevation for the town of Libby is 2,601 feet. The ridgetops surrounding Libby are approximately 4,000 feet higher than the town. The town sits in a narrow valley that runs in a north south direction ( 48 ° 23' 17" North, 6 352 115 ° 33' 13" West). The Kootenai River runs adjacent to the town in an east west direction. The Kootenai Basin is largely mountainous and dominated by three major ranges. The Rocky Mountain Range and the Flathead Range constitute the eastern boundary; the Purcell Range roughly bisects it from north to south. The Selkirk and Cabinet Ranges mark the western boundary. Elevations reach a maximum of about 12,000 feet with most summit elevations between 6,000 and 7,500 feet. Except for a few areas, the entire watershed is heavily forested ( practically all of Lincoln County and a large portion of the surrounding counties consists of National Forest land). The Kootenai River has its origins in British Columbia's Kootenay National Park in Canada. From there it flows 485 miles into northwest Montana and through the towns of Libby and Troy. From there it flows into northern Idaho, then back into Canada and Kootenay Lake. Ultimately it joins with the Columbia River. Sixteen miles north of Libby, the river is held back by Libby Dam, creating a 90 mile long reservoir that reaches into Canada. The river drops less than 1,000 feet ( 305 meters) in elevation from Canal Flats to Kootenay Lake, a distance of over 300 miles ( 480 km). However, even along the river's slow meandering course, valley bottom widths are generally less than two miles and are characterized by tree covered rolling hills with few grassland openings.

Due to the topographical features and meteorological data ( see factor 6 above) within and surrounding the vicinity of Libby resulting in stagnant weather conditions trapping emissions in the valley, EPA feels the adjacent counties do not impact the PM2.5 monitor located at the Libby Courthouse Annex. Emissions from adjacent counties would have to traverse one or more major mountain ranges, in some cases against the prevailing wind direction, in order to impact the town of Libby.

This factor played a significant role in the decision making process.

Factor 8: Jurisdictional boundaries No areas in Montana or Idaho were designated nonattainment for the 8 hour ozone standard on April 15, 2004.

The town of Libby and vicinity within Lincoln County are designated nonattainment for PM10.

Due to the fact that the town and surrounding vicinity of Libby, Montana was designated nonattainment for PM10 and did not include the surrounding counties around Lincoln, MT, EPA believes this factor plays a significant role in the decision making process.

Factor 9: Level of control of emission sources The following are sources located in Lincoln County, MT but are not considered major PSD sources.

 Plum Creek Northwest Lumber, Inc. ( Ksandka Sawmill), Fortine, MT  Eureka Pellet Mills, Eureka, MT 6 353  Genesis Inc. ( Troy Mine), Troy, MT  Lone Pine Timber Industries, Eureka, MT  Stimson Lumber Mill, Libby, MT ( closed  Spring, 2003)

Due to the topographical features and meteorology in Lincoln County ( see factors 6 and 7 below) and more specifically surrounding Libby, MT where the PM2.5 problem is located, EPA believes this factor does not play a significant role in the decision making process.

6.8.2 Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Background: In a letter dated February 25, 2004, the Governor of Montana submitted to EPA a letter recommending that the PM2.5 nonattainment boundary for Lincoln County, MT be designated as a partial county. The Governor's letter did not provide a specific justification for a partial county recommendation or identify what the partial county boundaries would be for Lincoln County. On June 29, 2004, EPA responded to Montana's recommendation stating that EPA agreed with Montana's recommended nonattainment designation for Lincoln County but that EPA intended to modify Montana's recommended boundary for the nonattainment area and designate the entire Lincoln County area as nonattainment for the PM2.5 national ambient air quality standards. 1 In two follow up letters from Montana dated June 25, 2004 and September 7, 2004, Montana identified specific PM2.5 nonattainment boundaries for Libby, MT along with a technical justification for the less than county request.

EPA's Recommended Change: Based upon EPA's review of Montana's letters dated June 25, 2004 and September 7, 2004 and subsequent discussions EPA has had with the Montana Department of Environmental Quality ( MT DEQ), EPA is modifying our original recommendation and identifying the PM2.5 nonattainment boundary area as follows: 600,000mE, 5,370,000mN east to 620,000mE, 5,370,000mN south to 620,000mE, 5,340,000mN west to 600,000mE, 5,340,000mN north to 600,000mE, 5,370,000mN as identified in Montana's September 7, 2004 letter. EPA believes these boundaries are reasonable for the following reasons:

1 EPA's April 1, 2003 " Designations for the Fine Particle National Ambient Air Quality Standards" which states: " When a rural monitor violates the standard, EPA intends to apply a presumption that the nonattainment area shall include the full county in which the monitor is located. EPA will consider recommendations to adjust rural area nonattainment boundaries based on the same factors as it applies to urban areas, as discussed in question 5 above. Using these factors, a State or Tribe that recommends that a smaller area should be designated nonattainment should provide convincing evidence that the monitor is not representative of the full county, that the excluded portions of the county are not source areas contributing to the nonattainment, and that the excluded portions of the county are meeting the standard. Similarly, a State or Tribe may recommend that a larger area be designated nonattainment based on technical information relevant to these factors. Nevertheless, as discussed above, if nonattainment is demonstrably very localized and is attributable to localized sources, EPA intends to establish nonattainment area boundaries based on a case specific evaluation of the nature and extent of the problem." 6 354 1. As stated under factors 6 and 7 of EPA's factor analysis for Lincoln County, meteorology and geographical/ topographical features within and surrounding the town of Libby played a significant role in the decision making process and in EPA's consideration to modify the nonattainment boundary to only include the town of Libby and surrounding vicinity. ( See Factors 6 and 7 for more details.)

2. The MT DEQ conducted a winter monitoring study in the Libby, Montana area from November 2003 through March 2004. This information was submitted to EPA in MT DEQ's June 25, 2004 PM2.5 nonattainment boundary area recommendation for the town of Libby. The monitoring study showed that within the " T" shape basin where Libby Creek flows into the Kootenai River, significant drops in PM2.5 occur along the northwestern edge of the Libby valley as well as the northeastern edge of the valley. Wind speed results showed that there is very little wind in the Libby area during winter confirming that much higher concentrations in winter are related to stagnant weather conditions dominated by light winds and strong temperature inversions. As a result, meteorological conditions may trap emissions within the valley for many days. In MT DEQ's June 25, 2004 recommendation, MT DEQ acknowledged in the boundary analysis that while monitoring was not conducted further south than 3 miles from the town's center, MT DEQ was confident that the boundary that they recommended in their June 25 letter adequately surrounds the source area for the Libby PM2.5 nonattainment area. EPA disagreed with MT DEQ's southern boundary recommendation and in further discussions with MT DEQ, came to an agreement to extend the southern boundary area to include an additional 20,000 meter UTM Grids beyond what was recommended in MT DEQ's June 25, 2004 recommendation. This new boundary agreement is reflected in MT DEQ's letter dated September 7, 2004.

Due to the geographical/ topographical features and meteorological data within and surrounding the vicinity of Libby and the study performed by MT DEQ, EPA feels the surrounding Lincoln County area outside the recommended boundary area does not impact the PM2.5 monitor located at the Libby Courthouse Annex. Emissions from the surrounding area within Lincoln County would have to traverse one or more major mountain ranges, in some cases against the prevailing wind direction, in order to impact the town of Libby.