Standards of Performance for

Coal Preparation and Processing Plants

(40 CFR 60 subpart Y)

Response to Comments Received on

Proposed Amendments

(Published April 28, 2008; 73 FR 22901)

and

Supplemental Proposal

(Published May 27, 2009; 74 FR 25304)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

Research Triangle Park, NC 27711

September 2009

Table of Contents

  TOC \o "2-5" \h \z \t "Heading 1,1"   HYPERLINK \l "_Toc238622224" 1.0
 INTRODUCTION	  PAGEREF _Toc238622224 \h  1

 HYPERLINK \l "_Toc238622225" 2.0  APRIL 28, 2008 SUBPART Y AMENDMENT
PROPOSAL	  PAGEREF _Toc238622225 \h  9

 HYPERLINK \l "_Toc238622226" 2.1	Decision to Amend Subpart Y	  PAGEREF
_Toc238622226 \h  9

 HYPERLINK \l "_Toc238622227" 2.1.1	Adequacy of Information Collected
for Rulemaking	  PAGEREF _Toc238622227 \h  9

 HYPERLINK \l "_Toc238622228" 2.1.2	Adequacy of Best Demonstrated
Technology (BDT) Analysis	  PAGEREF _Toc238622228 \h  9

 HYPERLINK \l "_Toc238622229" 2.2	Subpart Y Applicability	  PAGEREF
_Toc238622229 \h  10

 HYPERLINK \l "_Toc238622230" 2.2.1	Coal Preparation Plant Definition
PAGEREF _Toc238622230 \h  10

 HYPERLINK \l "_Toc238622231" 2.2.2	Coal Preparation Plant Threshold
Throughput	  PAGEREF _Toc238622231 \h  11

 HYPERLINK \l "_Toc238622232" 2.2.3	Subpart Y Amendments Applicability
Date	  PAGEREF _Toc238622232 \h  12

 HYPERLINK \l "_Toc238622233" 2.3	Subpart Y Thermal Dryer Standards
PAGEREF _Toc238622233 \h  12

 HYPERLINK \l "_Toc238622234" 2.3.1	Thermal Dryers Processing
Non-Bituminous Coals	  PAGEREF _Toc238622234 \h  12

 HYPERLINK \l "_Toc238622235" 2.3.2	Thermal Dryer BDT Determination
PAGEREF _Toc238622235 \h  13

 HYPERLINK \l "_Toc238622236" <IP_ADDRESS>	Consideration of Alternative Coal
Drying Technologies as BDT	  PAGEREF _Toc238622236 \h  13

 HYPERLINK \l "_Toc238622237" <IP_ADDRESS>	Consideration of Add-on
Particulate Matter (PM) Emissions Control Technologies as BDT	  PAGEREF
_Toc238622237 \h  14

 HYPERLINK \l "_Toc238622238" 2.3.4	Thermal Dryer PM Emissions Limits
PAGEREF _Toc238622238 \h  15

 HYPERLINK \l "_Toc238622239" <IP_ADDRESS>	Promulgation of PM Emission Limits
Based on Fabric Filters as BDT	  PAGEREF _Toc238622239 \h  15

 HYPERLINK \l "_Toc238622240" <IP_ADDRESS>	Establish Separate Emissions
Limits for PM2.5, PM10, and Condensible PM	  PAGEREF _Toc238622240 \h
15

 HYPERLINK \l "_Toc238622241" <IP_ADDRESS>	Selection of Proposed Emission
Limit Value	  PAGEREF _Toc238622241 \h  16

 HYPERLINK \l "_Toc238622242" <IP_ADDRESS>	Continuous Achievability of
Proposed Emission Limit Value	  PAGEREF _Toc238622242 \h  17

 HYPERLINK \l "_Toc238622243" <IP_ADDRESS>	Modified and Reconstructed Sources
  PAGEREF _Toc238622243 \h  18

 HYPERLINK \l "_Toc238622244" 2.3.5	Thermal Dryer Opacity Limit
PAGEREF _Toc238622244 \h  18

 HYPERLINK \l "_Toc238622245" 2.3.6	Thermal Dryer SO2 and NOx Emissions
Limits	  PAGEREF _Toc238622245 \h  19

 HYPERLINK \l "_Toc238622246" 2.3.7	Thermal Dryer Volatile Organic
Compounds (VOC) Emissions Limit	  PAGEREF _Toc238622246 \h  19

 HYPERLINK \l "_Toc238622247" 2.3.8	Thermal Dryers with In-line Coal
Mills	  PAGEREF _Toc238622247 \h  19

 HYPERLINK \l "_Toc238622248" 2.4	Subpart Y Coal Processing, Conveying,
Storage and Transfer System Standards	  PAGEREF _Toc238622248 \h  20

 HYPERLINK \l "_Toc238622249" 2.4.1	Affected Sources	  PAGEREF
_Toc238622249 \h  20

 HYPERLINK \l "_Toc238622250" <IP_ADDRESS>	Coal Processing and Conveying
Equipment	  PAGEREF _Toc238622250 \h  20

 HYPERLINK \l "_Toc238622251" <IP_ADDRESS>	Coal Unloading Activities
PAGEREF _Toc238622251 \h  21

 HYPERLINK \l "_Toc238622252" <IP_ADDRESS>	Coal Storage Piles	  PAGEREF
_Toc238622252 \h  22

 HYPERLINK \l "_Toc238622253" <IP_ADDRESS>	Plant Roads	  PAGEREF
_Toc238622253 \h  22

 HYPERLINK \l "_Toc238622254" <IP_ADDRESS>	Coal Hauling Trucks and Railcars
PAGEREF _Toc238622254 \h  23

 HYPERLINK \l "_Toc238622255" <IP_ADDRESS>	Coal Sampling Systems	  PAGEREF
_Toc238622255 \h  23

 HYPERLINK \l "_Toc238622256" <IP_ADDRESS>	Coal Mine Portable Screens
PAGEREF _Toc238622256 \h  23

 HYPERLINK \l "_Toc238622257" 2.4.2	Subcategorization of Standards by
Coal Rank	  PAGEREF _Toc238622257 \h  24

 HYPERLINK \l "_Toc238622258" <IP_ADDRESS>	Relationship of Coal Rank to Coal
Dust Emissions Control	  PAGEREF _Toc238622258 \h  24

 HYPERLINK \l "_Toc238622259" <IP_ADDRESS>	Coal Rank Subcategorization
Inconsistent with Existing Policy	  PAGEREF _Toc238622259 \h  24

 HYPERLINK \l "_Toc238622260" <IP_ADDRESS>	Anthracite Coal	  PAGEREF
_Toc238622260 \h  25

 HYPERLINK \l "_Toc238622261" <IP_ADDRESS>	Blended Coals	  PAGEREF
_Toc238622261 \h  25

 HYPERLINK \l "_Toc238622262" <IP_ADDRESS>	Impact on Facility Fuel
Flexibility	  PAGEREF _Toc238622262 \h  26

 HYPERLINK \l "_Toc238622263" 2.4.3	BDT Determination	  PAGEREF
_Toc238622263 \h  26

 HYPERLINK \l "_Toc238622264" <IP_ADDRESS>	Equivalency of Fabric Filter and
Chemical Suppression Control Systems	  PAGEREF _Toc238622264 \h  26

 HYPERLINK \l "_Toc238622265" <IP_ADDRESS>	Consideration of Alternative Coal
Dust Control Technologies as BDT	  PAGEREF _Toc238622265 \h  27

 HYPERLINK \l "_Toc238622266" 2.4.4	Fabric Filters (Baghouses)	  PAGEREF
_Toc238622266 \h  28

 HYPERLINK \l "_Toc238622267" <IP_ADDRESS>	Fabric Filter Safety	  PAGEREF
_Toc238622267 \h  28

 HYPERLINK \l "_Toc238622268" <IP_ADDRESS>	Fabric Filter Performance
PAGEREF _Toc238622268 \h  28

 HYPERLINK \l "_Toc238622269" <IP_ADDRESS>	Fabric Filter Dust Disposal
PAGEREF _Toc238622269 \h  28

 HYPERLINK \l "_Toc238622270" 2.4.5	Conveyor System Enclosures	  PAGEREF
_Toc238622270 \h  29

 HYPERLINK \l "_Toc238622271" <IP_ADDRESS>	Enclosure Fugitive Dust Emission
Points	  PAGEREF _Toc238622271 \h  29

 HYPERLINK \l "_Toc238622272" <IP_ADDRESS>	Enclosure Safety	  PAGEREF
_Toc238622272 \h  29

 HYPERLINK \l "_Toc238622273" 2.4.6	PM Emission Limits	  PAGEREF
_Toc238622273 \h  29

 HYPERLINK \l "_Toc238622274" <IP_ADDRESS>	Applicability of PM Emission
Limits	  PAGEREF _Toc238622274 \h  29

 HYPERLINK \l "_Toc238622275" <IP_ADDRESS>	Fenceline Ambient Air Monitoring
of Coal Preparation Facilities	  PAGEREF _Toc238622275 \h  30

 HYPERLINK \l "_Toc238622276" <IP_ADDRESS>	Condensible PM Emission Limits
PAGEREF _Toc238622276 \h  30

 HYPERLINK \l "_Toc238622277" <IP_ADDRESS>     Selection of Proposed PM
Emission Limit Level	  PAGEREF _Toc238622277 \h  30

 HYPERLINK \l "_Toc238622278" 2.4.7	Opacity Limits	  PAGEREF
_Toc238622278 \h  31

 HYPERLINK \l "_Toc238622279" <IP_ADDRESS>	Method 9 Accuracy and Limitations
 PAGEREF _Toc238622279 \h  31

 HYPERLINK \l "_Toc238622280" <IP_ADDRESS>	Selection of Proposed Opacity
Limit Level	  PAGEREF _Toc238622280 \h  32

 HYPERLINK \l "_Toc238622281" <IP_ADDRESS>	Fabric Filters	  PAGEREF
_Toc238622281 \h  32

 HYPERLINK \l "_Toc238622282" <IP_ADDRESS>	Fugitive Emissions Sources
PAGEREF _Toc238622282 \h  32

 HYPERLINK \l "_Toc238622283" <IP_ADDRESS>	Coal Storage Silos	  PAGEREF
_Toc238622283 \h  33

 HYPERLINK \l "_Toc238622284" 2.4.8	Work Practice Standards	  PAGEREF
_Toc238622284 \h  33

 HYPERLINK \l "_Toc238622285" <IP_ADDRESS>	Alternative to Opacity Standards
PAGEREF _Toc238622285 \h  33

 HYPERLINK \l "_Toc238622286" <IP_ADDRESS>	Coal Storage Piles	  PAGEREF
_Toc238622286 \h  34

 HYPERLINK \l "_Toc238622287" <IP_ADDRESS>	Coal Truck Dumps	  PAGEREF
_Toc238622287 \h  35

 HYPERLINK \l "_Toc238622288" 2.4.9	Modified/Reconstructed Sources
PAGEREF _Toc238622288 \h  35

 HYPERLINK \l "_Toc238622289" <IP_ADDRESS>	Routine Equipment Maintenance and
Repair	  PAGEREF _Toc238622289 \h  35

 HYPERLINK \l "_Toc238622290" <IP_ADDRESS>	Modified Sources	  PAGEREF
_Toc238622290 \h  35

 HYPERLINK \l "_Toc238622291" <IP_ADDRESS>	Reconstructed Sources	  PAGEREF
_Toc238622291 \h  36

 HYPERLINK \l "_Toc238622292" 2.4.10	Consistency with Relevant
Requirements in Nonmetallic Mineral Processing NSPS	  PAGEREF
_Toc238622292 \h  37

 HYPERLINK \l "_Toc238622293" 2.5	Subpart Y Implementation Requirements
 PAGEREF _Toc238622293 \h  38

 HYPERLINK \l "_Toc238622294" 2.5.1	PM Emissions Performance Testing
PAGEREF _Toc238622294 \h  38

 HYPERLINK \l "_Toc238622295" <IP_ADDRESS>	Need for PM Performance Test
PAGEREF _Toc238622295 \h  38

 HYPERLINK \l "_Toc238622296" <IP_ADDRESS>	Performance Testing of Small
Fabric Filters	  PAGEREF _Toc238622296 \h  38

 HYPERLINK \l "_Toc238622297" <IP_ADDRESS>	PM Performance Test Interval
PAGEREF _Toc238622297 \h  38

 HYPERLINK \l "_Toc238622298" <IP_ADDRESS>	Use of Method 17 as Alternative PM
Test Method	  PAGEREF _Toc238622298 \h  39

 HYPERLINK \l "_Toc238622299" 2.5.2	Visible Emissions Monitoring
PAGEREF _Toc238622299 \h  40

 HYPERLINK \l "_Toc238622300" <IP_ADDRESS>	Periodic Visible Emissions
Monitoring Frequency	  PAGEREF _Toc238622300 \h  40

 HYPERLINK \l "_Toc238622301" <IP_ADDRESS>	Visible Emissions Monitoring
Frequency for Fogging Systems and Passive Enclosure Containment System
(PECS)	  PAGEREF _Toc238622301 \h  40

 HYPERLINK \l "_Toc238622302" <IP_ADDRESS>	Method 22 Observation Period
PAGEREF _Toc238622302 \h  41

 HYPERLINK \l "_Toc238622303" <IP_ADDRESS>	Method 9 Performance Test Trigger
 PAGEREF _Toc238622303 \h  41

 HYPERLINK \l "_Toc238622304" <IP_ADDRESS>	Wet Process Visible Emission
Monitoring Exemption	  PAGEREF _Toc238622304 \h  42

 HYPERLINK \l "_Toc238622305" <IP_ADDRESS>	Alternative Site-Specific Test
Method	  PAGEREF _Toc238622305 \h  42

 HYPERLINK \l "_Toc238622306" 2.5.3	Bag Leak Detector System (BLDS)
PAGEREF _Toc238622306 \h  43

 HYPERLINK \l "_Toc238622307" <IP_ADDRESS>	BLDS Cost Impact	  PAGEREF
_Toc238622307 \h  43

 HYPERLINK \l "_Toc238622308" <IP_ADDRESS>	BLDS Operation under Adverse
Weather	  PAGEREF _Toc238622308 \h  43

 HYPERLINK \l "_Toc238622309" 2.5.4	PM Continuous Emission Monitoring
System (CEMS)	  PAGEREF _Toc238622309 \h  43

 HYPERLINK \l "_Toc238622310" 2.5.5	Continuous Opacity Monitor System
(COMS)	  PAGEREF _Toc238622310 \h  44

 HYPERLINK \l "_Toc238622311" 2.5.6	Recordkeeping	  PAGEREF
_Toc238622311 \h  45

 HYPERLINK \l "_Toc238622312" <IP_ADDRESS>	General	  PAGEREF _Toc238622312 \h
 45

 HYPERLINK \l "_Toc238622313" <IP_ADDRESS>	Fogging Systems	  PAGEREF
_Toc238622313 \h  45

 HYPERLINK \l "_Toc238622314" <IP_ADDRESS>	Dust Suppressant System
Non-operating Periods	  PAGEREF _Toc238622314 \h  46

 HYPERLINK \l "_Toc238622315" 2.6	Analyses of Cost, Non-air, and Energy
Impacts	  PAGEREF _Toc238622315 \h  46

 HYPERLINK \l "_Toc238622316" 2.6.1	Adequacy of Cost Analysis	  PAGEREF
_Toc238622316 \h  46

 HYPERLINK \l "_Toc238622317" 2.6.2	Adequacy of Non-air Impacts and
Energy Requirement Analyses	  PAGEREF _Toc238622317 \h  47

 HYPERLINK \l "_Toc238622318" 2.7	Relationship of Subpart Y with Other
Rules	  PAGEREF _Toc238622318 \h  47

 HYPERLINK \l "_Toc238622319" 2.7.1	Part 70 Title V Permits	  PAGEREF
_Toc238622319 \h  47

 HYPERLINK \l "_Toc238622320" 2.7.2	Nonmetallic Mineral Processing
Plants NSPS (40 CFR 60 subpart OOO)	  PAGEREF _Toc238622320 \h  48

 HYPERLINK \l "_Toc238622321" 2.7.3	Occupational Safety and Health
Administration (OSHA) Rules	  PAGEREF _Toc238622321 \h  49

 HYPERLINK \l "_Toc238622322" 2.8	Proposed Regulatory Text
Clarifications	  PAGEREF _Toc238622322 \h  49

 HYPERLINK \l "_Toc238622323" 3.0  May 27, 2009, Supplemental Subpart Y
Amendment Proposal	  PAGEREF _Toc238622323 \h  51

 HYPERLINK \l "_Toc238622324" 3.1	Subpart Y Applicability	  PAGEREF
_Toc238622324 \h  51

 HYPERLINK \l "_Toc238622325" 3.1.1	Regulated Pollutants	  PAGEREF
_Toc238622325 \h  51

 HYPERLINK \l "_Toc238622326" <IP_ADDRESS>	SO2, NOx or CO Endangerment
Finding	  PAGEREF _Toc238622326 \h  51

 HYPERLINK \l "_Toc238622327" <IP_ADDRESS>	Standards for Greenhouse Gas
Emissions	  PAGEREF _Toc238622327 \h  53

 HYPERLINK \l "_Toc238622328" 3.1.2	Addition of Coal Refuse to
Definition of “Coal”	  PAGEREF _Toc238622328 \h  54

 HYPERLINK \l "_Toc238622329" 3.1.3	Subpart Y Amendments Applicability
Dates	  PAGEREF _Toc238622329 \h  54

 HYPERLINK \l "_Toc238622330" 3.1.4	Affected Facilities - General
PAGEREF _Toc238622330 \h  55

 HYPERLINK \l "_Toc238622331" 3.1.5	Affected Facilities at Existing Coal
Preparation Plants	  PAGEREF _Toc238622331 \h  56

 HYPERLINK \l "_Toc238622332" 3.2	Subpart Y Subcategorization	  PAGEREF
_Toc238622332 \h  56

 HYPERLINK \l "_Toc238622333" 3.3	Subpart Y Coal Drying Standards
PAGEREF _Toc238622333 \h  59

 HYPERLINK \l "_Toc238622334" 3.3.1	Affected Coal Dryers	  PAGEREF
_Toc238622334 \h  59

 HYPERLINK \l "_Toc238622335" <IP_ADDRESS>	Indirect Thermal Coal Dryers
PAGEREF _Toc238622335 \h  59

 HYPERLINK \l "_Toc238622336" <IP_ADDRESS>	Fluidized-bed Thermal Coal Dryers
 PAGEREF _Toc238622336 \h  60

 HYPERLINK \l "_Toc238622337" <IP_ADDRESS>	New Coal Dryer Projections
PAGEREF _Toc238622337 \h  60

 HYPERLINK \l "_Toc238622338" 3.3.2	Coal Drying BDT Determination
PAGEREF _Toc238622338 \h  60

 HYPERLINK \l "_Toc238622339" <IP_ADDRESS>	BDT Analysis for Coal Drying
PAGEREF _Toc238622339 \h  60

 HYPERLINK \l "_Toc238622340" <IP_ADDRESS>	BDT for Coal Drying	  PAGEREF
_Toc238622340 \h  64

 HYPERLINK \l "_Toc238622341" 3.3.3	Coal Dryer Emission Limits Standards
Format	  PAGEREF _Toc238622341 \h  65

 HYPERLINK \l "_Toc238622342" 3.3.4	Coal Dryer PM Emission Limits
PAGEREF _Toc238622342 \h  66

 HYPERLINK \l "_Toc238622343" <IP_ADDRESS>	Filterable PM (FPM) and
Condensable PM (CPM) Standards	  PAGEREF _Toc238622343 \h  66

 HYPERLINK \l "_Toc238622344" <IP_ADDRESS>	PM Control Technology Terminology
 PAGEREF _Toc238622344 \h  67

 HYPERLINK \l "_Toc238622345" <IP_ADDRESS>	New Coal Dryer PM Emission Limit
“Margin of Compliance”	  PAGEREF _Toc238622345 \h  67

 HYPERLINK \l "_Toc238622346" <IP_ADDRESS>	Reconstructed Coal Dryer PM
Emission Limits	  PAGEREF _Toc238622346 \h  68

 HYPERLINK \l "_Toc238622347" <IP_ADDRESS>	Modified Coal Dryer PM Emission
Limits	  PAGEREF _Toc238622347 \h  69

 HYPERLINK \l "_Toc238622348" 3.3.5	Coal Dryer SO2 Emission Limit
PAGEREF _Toc238622348 \h  69

 HYPERLINK \l "_Toc238622349" <IP_ADDRESS>	BDT Determination Cost Analysis
PAGEREF _Toc238622349 \h  69

 HYPERLINK \l "_Toc238622350" <IP_ADDRESS>	BDT Determination Control
Technology Options	  PAGEREF _Toc238622350 \h  70

 HYPERLINK \l "_Toc238622351" <IP_ADDRESS>	SO2 Emission Limit Levels
PAGEREF _Toc238622351 \h  71

 HYPERLINK \l "_Toc238622352" 3.3.6	Coal Dryer Combined NOx /CO Emission
Limit	  PAGEREF _Toc238622352 \h  72

 HYPERLINK \l "_Toc238622353" 3.3.7	Coal Dryer VOC Emissions Limit
PAGEREF _Toc238622353 \h  73

 HYPERLINK \l "_Toc238622354" 3.3.8	Applicability to Coal Dryers at
Cement Manufacturing Plants	  PAGEREF _Toc238622354 \h  74

 HYPERLINK \l "_Toc238622355" 3.3.9	Applicability to Coal Dryers at
Steel Manufacturing Plants	  PAGEREF _Toc238622355 \h  76

 HYPERLINK \l "_Toc238622356" 3.4	Subpart Y Coal Processing, Conveying,
Storage and Transfer System Standards	  PAGEREF _Toc238622356 \h  77

 HYPERLINK \l "_Toc238622357" 3.4.1	Affected Sources	  PAGEREF
_Toc238622357 \h  77

 HYPERLINK \l "_Toc238622358" <IP_ADDRESS>	Coal Unloading Activities -
Subpart Y Proposal Contrary to EPA Policy	  PAGEREF _Toc238622358 \h  77

 HYPERLINK \l "_Toc238622361" <IP_ADDRESS>	Coal Storage Piles	 79

 HYPERLINK \l "_Toc238622362" <IP_ADDRESS>.1	Authority to Regulate Coal
Storage Piles under Subpart Y	79

 HYPERLINK \l "_Toc238622363" <IP_ADDRESS>.2	Site-specific Coal Pile Emission
Characteristics	  PAGEREF _Toc238622363 \h  80

 HYPERLINK \l "_Toc238622364" <IP_ADDRESS>.3	Inclusion of Open Storage Piles
in Definition of “Coal Storage System”	  PAGEREF _Toc238622364 \h
81

 HYPERLINK \l "_Toc238622365" <IP_ADDRESS>.4	Coal Piles Loaded in Trucks,
Railcars, and Ships	  PAGEREF _Toc238622365 \h  82

 HYPERLINK \l "_Toc238622366" <IP_ADDRESS>	Coal Preparation Plant Roadways
PAGEREF _Toc238622366 \h  83

 HYPERLINK \l "_Toc238622367" <IP_ADDRESS>	Coal Sampling Systems	  PAGEREF
_Toc238622367 \h  85

 HYPERLINK \l "_Toc238622368" 3.4.2	Relationship of Subpart Y
Requirements to Other Rules	  PAGEREF _Toc238622368 \h  85

 HYPERLINK \l "_Toc238622369" <IP_ADDRESS>	Nonmetallic Mineral Processing
NSPS (40 CFR 60 subpart OOO)	  PAGEREF _Toc238622369 \h  85

 HYPERLINK \l "_Toc238622370" <IP_ADDRESS>	Surface Mining Control and
Reclamation Act (SMCRA)	  PAGEREF _Toc238622370 \h  87

 HYPERLINK \l "_Toc238622371" 3.4.3	BDT Determination	  PAGEREF
_Toc238622371 \h  87

 HYPERLINK \l "_Toc238622372" 3.4.4	PM Emission Limits	  PAGEREF
_Toc238622372 \h  88

 HYPERLINK \l "_Toc238622373" <IP_ADDRESS>	Applicability of PM Emission
Limits	  PAGEREF _Toc238622373 \h  88

 HYPERLINK \l "_Toc238622374" <IP_ADDRESS>	Selection of Proposed PM Emission
Limit Level	  PAGEREF _Toc238622374 \h  88

 HYPERLINK \l "_Toc238622375" 3.4.5	Opacity Standards	  PAGEREF
_Toc238622375 \h  88

 HYPERLINK \l "_Toc238622376" <IP_ADDRESS>	Opacity Standards for Open Storage
Piles and Roadways	  PAGEREF _Toc238622376 \h  88

 HYPERLINK \l "_Toc238622377" <IP_ADDRESS>	Proposed Opacity Limit Level
PAGEREF _Toc238622377 \h  90

 HYPERLINK \l "_Toc238622378" <IP_ADDRESS>.1	Insufficient Representative Data
  PAGEREF _Toc238622378 \h  90

 HYPERLINK \l "_Toc238622379" <IP_ADDRESS>.2	Continuous Achievability of
Opacity Limit	  PAGEREF _Toc238622379 \h  90

 HYPERLINK \l "_Toc238622380" <IP_ADDRESS>.3	Selection of Proposed Opacity
Limit Level	  PAGEREF _Toc238622380 \h  91

 HYPERLINK \l "_Toc238622381" <IP_ADDRESS>.4	Alternative to Opacity Limit
PAGEREF _Toc238622381 \h  93

 HYPERLINK \l "_Toc238622382" 3.4.6	PM Emissions Controls and Work
Practice Standards	  PAGEREF _Toc238622382 \h  93

 HYPERLINK \l "_Toc238622383" <IP_ADDRESS>	Coal Conveyors	  PAGEREF
_Toc238622383 \h  93

 HYPERLINK \l "_Toc238622384" <IP_ADDRESS>	Coal Storage Piles	  PAGEREF
_Toc238622384 \h  94

 HYPERLINK \l "_Toc238622385" <IP_ADDRESS>.1	Work Practice Standards
PAGEREF _Toc238622385 \h  94

 HYPERLINK \l "_Toc238622386" <IP_ADDRESS>.2	Enclosure of Coal Storage Piles
 PAGEREF _Toc238622386 \h  94

 HYPERLINK \l "_Toc238622387" <IP_ADDRESS>	Coal Preparation Plant Roadways
PAGEREF _Toc238622387 \h  95

 HYPERLINK \l "_Toc238622388" <IP_ADDRESS>.1	Coal Haul Road Exemption
PAGEREF _Toc238622388 \h  95

 HYPERLINK \l "_Toc238622389" <IP_ADDRESS>.2	Truck Washes	  PAGEREF
_Toc238622389 \h  96

 HYPERLINK \l "_Toc238622390" <IP_ADDRESS>.3	Weather-Related Exemptions
PAGEREF _Toc238622390 \h  96

 HYPERLINK \l "_Toc238622391" <IP_ADDRESS>	Coal Truck Dumps	  PAGEREF
_Toc238622391 \h  96

 HYPERLINK \l "_Toc238622392" <IP_ADDRESS>	Affected Facilities in Enclosed
Buildings	  PAGEREF _Toc238622392 \h  97

 HYPERLINK \l "_Toc238622393" <IP_ADDRESS>	Site-Specific Fugitive Emission
Control Plan	  PAGEREF _Toc238622393 \h  98

 HYPERLINK \l "_Toc238622394" <IP_ADDRESS>.1	Need for Plan in Subpart Y
PAGEREF _Toc238622394 \h  98

 HYPERLINK \l "_Toc238622395" <IP_ADDRESS>.2	Plan Requirements	  PAGEREF
_Toc238622395 \h  99

 HYPERLINK \l "_Toc238622396" <IP_ADDRESS>.3	Plan Implementation	  PAGEREF
_Toc238622396 \h  100

 HYPERLINK \l "_Toc238622397" <IP_ADDRESS>.4	Plan Submittal Date	  PAGEREF
_Toc238622397 \h  101

 HYPERLINK \l "_Toc238622398" 3.4.7	Reconstructed and Modified Sources
PAGEREF _Toc238622398 \h  102

 HYPERLINK \l "_Toc238622399" <IP_ADDRESS>	Coal Storage Piles	  PAGEREF
_Toc238622399 \h  102

 HYPERLINK \l "_Toc238622400" <IP_ADDRESS>	Coal Preparation Plant Roadways
PAGEREF _Toc238622400 \h  102

 HYPERLINK \l "_Toc238622401" 3.5	Subpart Y Testing and Monitoring
Requirements	  PAGEREF _Toc238622401 \h  103

 HYPERLINK \l "_Toc238622402" 3.5.1	PM Emissions Testing	  PAGEREF
_Toc238622402 \h  103

 HYPERLINK \l "_Toc238622403" <IP_ADDRESS>	PM Performance Test Frequency
PAGEREF _Toc238622403 \h  103

 HYPERLINK \l "_Toc238622404" <IP_ADDRESS>	Small Fabric Filters PM
Performance Test Exemption	  PAGEREF _Toc238622404 \h  104

 HYPERLINK \l "_Toc238622405" <IP_ADDRESS>	Performance Test Delay for
Non-operating Affected Sources	  PAGEREF _Toc238622405 \h  104

 HYPERLINK \l "_Toc238622406" <IP_ADDRESS>	Use of Method 17 as Alternative PM
Test Method	  PAGEREF _Toc238622406 \h  105

 HYPERLINK \l "_Toc238622407" <IP_ADDRESS>	Performance Testing of Multiple
Similar Affected Facilities	  PAGEREF _Toc238622407 \h  105

 HYPERLINK \l "_Toc238622408" 3.5.2	Visible Emissions Testing	  PAGEREF
_Toc238622408 \h  107

 HYPERLINK \l "_Toc238622409" <IP_ADDRESS>	Need for Method 9 Performance
Tests	  PAGEREF _Toc238622409 \h  107

 HYPERLINK \l "_Toc238622410" <IP_ADDRESS>	Method 9 Accuracy and Limitations
 PAGEREF _Toc238622410 \h  107

 HYPERLINK \l "_Toc238622411" <IP_ADDRESS>	Method 9 Observation Period
PAGEREF _Toc238622411 \h  108

 HYPERLINK \l "_Toc238622412" <IP_ADDRESS>	Method 9 Repeat Performance Test
Frequency	  PAGEREF _Toc238622412 \h  108

 HYPERLINK \l "_Toc238622413" <IP_ADDRESS>	Method 9 Application to Affected
Sources in Enclosures	  PAGEREF _Toc238622413 \h  111

 HYPERLINK \l "_Toc238622414" 3.5.3	Periodic Visible Emissions
Compliance Monitoring	  PAGEREF _Toc238622414 \h  112

 HYPERLINK \l "_Toc238622415" <IP_ADDRESS>	Visible Emissions Monitoring
Procedure	  PAGEREF _Toc238622415 \h  112

 HYPERLINK \l "_Toc238622416" <IP_ADDRESS>	Coal Truck Dump Monitoring
PAGEREF _Toc238622416 \h  114

 HYPERLINK \l "_Toc238622417" 3.5.4	CEMS	  PAGEREF _Toc238622417 \h  116

 HYPERLINK \l "_Toc238622418" 3.5.5	COMS Alternative	  PAGEREF
_Toc238622418 \h  118

 HYPERLINK \l "_Toc238622419" 3.5.6	Digital Opacity Compliance System
Alternative	  PAGEREF _Toc238622419 \h  119

 HYPERLINK \l "_Toc238622420" <IP_ADDRESS>	Digital Opacity Compliance System
in Subpart Y Rulemaking	  PAGEREF _Toc238622420 \h  119

 HYPERLINK \l "_Toc238622421" <IP_ADDRESS>	Digital Opacity Compliance System
Implementation	  PAGEREF _Toc238622421 \h  119

 HYPERLINK \l "_Toc238622422" 3.5.7	Process and Control Device Operation
Monitoring	  PAGEREF _Toc238622422 \h  120

 HYPERLINK \l "_Toc238622423" <IP_ADDRESS>	Fabric Filter Bag Leak Detection
Systems (BLDS)	  PAGEREF _Toc238622423 \h  120

 HYPERLINK \l "_Toc238622424" <IP_ADDRESS>	Wet Scrubber Operating Parameters
 PAGEREF _Toc238622424 \h  121

 HYPERLINK \l "_Toc238622425" <IP_ADDRESS>	Coal Dryer Temperature Monitoring
 PAGEREF _Toc238622425 \h  121

 HYPERLINK \l "_Toc238622426" 3.5.8	Recordkeeping and Reporting
PAGEREF _Toc238622426 \h  121

 HYPERLINK \l "_Toc238622427" <IP_ADDRESS>	General	  PAGEREF _Toc238622427 \h
 121

 HYPERLINK \l "_Toc238622428" <IP_ADDRESS>	Electronic Compliance Data
Reporting to EPA Data Base	  PAGEREF _Toc238622428 \h  123

 HYPERLINK \l "_Toc238622429" 3.6	Petroleum Coke	 125

 HYPERLINK \l "_Toc238622430" 3.6.1	Applicability of Subpart Y to
Petroleum Coke Producers	  PAGEREF _Toc238622430 \h  125

 HYPERLINK \l "_Toc238622431" 3.6.2	Applicability of Subpart Y to
Petroleum Coke Users	  PAGEREF _Toc238622431 \h  127

 HYPERLINK \l "_Toc238622432" 3.6.3	Petroleum Coke Calciners are not
Coal Thermal Dryers	  PAGEREF _Toc238622432 \h  127

 HYPERLINK \l "_Toc238622433" 3.6.4	Definition of Fugitive Emissions
PAGEREF _Toc238622433 \h  127

 HYPERLINK \l "_Toc238622434" 3.7	Subpart Y Amendments Impact Analyses
PAGEREF _Toc238622434 \h  128

 HYPERLINK \l "_Toc238622435" 3.7.1	Cost and Economic Analyses	  PAGEREF
_Toc238622435 \h  128

 HYPERLINK \l "_Toc238622436" 3.7.2	Environmental Impacts of Chemical
Dust Suppressant Use	  PAGEREF _Toc238622436 \h  129

 HYPERLINK \l "_Toc238622437" 3.7.3	Information Collection Request (ICR)
Burden Analysis	  PAGEREF _Toc238622437 \h  130

 HYPERLINK \l "_Toc238622438" 3.8	Regulatory Text Clarifications
PAGEREF _Toc238622438 \h  131

 HYPERLINK \l "_Toc238622439" 3.8.1	Subpart Y Title	  PAGEREF
_Toc238622439 \h  131

 HYPERLINK \l "_Toc238622440" 3.8.2	Use of Term “Coal Handling”
PAGEREF _Toc238622440 \h  131

 HYPERLINK \l "_Toc238622441" 3.8.3	Subpart Y Rule Citation Errors
PAGEREF _Toc238622441 \h  132

 HYPERLINK \l "_Toc238622442" 3.9	Other Comments	  PAGEREF _Toc238622442
\h  132

List of Tables

  TOC \h \z \t "Title_Table,1"   HYPERLINK \l "_Toc237056728" 1-1	List
of Commenters on Amendments to 40 CFR 60 subpart Y Proposed April 28,
2008 (73 FR 22901)	  PAGEREF _Toc237056728 \h  2

 HYPERLINK \l "_Toc237056729" 1-2	List of Commenters on Amendments to 40
CFR 60 subpart Y Proposed May 27, 2009 (74 FR 25304)	  PAGEREF
_Toc237056729 \h  6

Acronyms and Abbreviations

BACT

Best Available Control Technology

BLDS

Bag Leak Detector System

BDT

Best Demonstrated Technology

CAA

Clean Air Act

CAM

Compliance Assurance Monitoring

CEMS

Continuous emission monitoring system

CO

Carbon monoxide

COMS

Continuous opacity monitoring system

CPM

Condensable particulate matter

EPA

U.S. Environmental Protection Agency

FPM

Filterable particulate matter

gr/dscf

grains per dry standard cubic foot

Mg

Mg/day

ICR

Megagrams

Megagrams per day

Information Collection Request

MSDS

Material Safety Data Sheets

MSHA

Mine Safety and Health Administration

NAAQS

National Ambient Air Quality Standards

NESHAPS

National Emission Standards for Hazardous Air Pollutants

NFPA

National Fire Protection Association

NSPS

New Source Performance Standards

NOx

Nitrogen oxides

O&M

Operation and maintenance

OSHA

Occupational Safety and Health Administration

PECS

Passive enclosure containment system

PM

PM2.5

PM10

Particulate matter

PM with an aerodynamic diameter less than or equal to a nominal 2.5 μ

PM with an aerodynamic diameter less than or equal to a nominal 10 μ

PSD

Prevention of Significant Deterioration

scfm

Standard cubic feet per minute

SO2

SMCRA

Subpart OOO

Subpart Y

Sulfur dioxide

Surface Mining Control and Reclamation Act

Nonmetallic mineral processing NSPS under 40 CFR 60 subpart OOO

Coal preparation and processing plants NSPS under 40 CFR 60 subpart Y

ton/day

tons per day

ton/yr

μ

tons per year

micrometers

VOC

Volatile organic compounds

WDEQ

Wyoming Department of Environmental Quality

1.0  INTRODUCTION

The U.S. Environmental Protection Agency (EPA or the Agency) proposed on
April 28, 2008 (see 73 FR 22901), amendments to the new source
performance standards (NSPS) for coal preparation and processing plants
in 40 CFR 60 subpart Y (hereafter referred to in this document as
“Subpart Y”).  Initially, a 45-day period ending June 12, 2008, was
provided for the public to submit comments to EPA regarding the proposed
Subpart Y amendments.  In response to a request from commenters, EPA
extended the public comment period an additional 30 days, and the
comment period ended July 12, 2008.

A total of 42 sets of comments were received by EPA regarding the April
28, 2008, proposed Subpart Y amendments.  Some of the comment sets were
signed or submitted on behalf of multiple commenters.  Also, in some
cases duplicate comment sets from the same commenter were submitted to
the EPA’s Air and Radiation Docket.  Table 1-1 lists the names of the
commenters, the commenters’ affiliations, and the Air and Radiation
Docket entry number for each of the comment sets submitted to EPA.  Some
commenters also submitted supplemental information and data to support
their comments.

After reviewing and considering the comments on the April 28, 2008,
proposed Subpart Y amendments, EPA decided to publish, and request
additional public comment on, a supplemental Subpart Y amendment
proposal.  This supplemental Subpart Y amendment proposal was published
on May 27, 2009 (see 74 FR 25304).  The supplemental Subpart Y amendment
proposal included: 1) revisions to the particulate matter (PM) emissions
and opacity limits originally proposed for thermal dryers, pneumatic
coal-cleaning equipment, and coal handling equipment (includes coal
processing, conveying, storage and transfer operations); 2) revisions
expanding the applicability of Subpart Y thermal dryer standards to both
direct contact and indirect contact thermal dryers drying all coal
ranks; 3) revisions expanding the applicability of Subpart Y pneumatic
coal-cleaning equipment standards to cleaning of all coal ranks; 4) a
new sulfur dioxide (SO2) and a new combined nitrogen oxides (NOx) and
carbon monoxide (CO) emissions limit for thermal dryers; 5) revisions to
the definition of “coal” to include petroleum coke and coal refuse;
6) addition of new work practice standards to control coal dust
emissions from open storage piles and roadways within with coal
preparation and processing plants, and 7) revisions to the monitoring
requirements.

A total of 44 sets of comments were received by EPA regarding the May
27, 2009, supplemental Subpart Y amendment proposal.  Table 1-2 lists
the names of the commenters, the commenters’ affiliations, and the EPA
Office of Air and Radiation Docket entry number for each of the comment
sets submitted to EPA regarding the supplemental Subpart Y amendment
proposal.

This document presents EPA’s response to each substantive comment
received by EPA on the proposed amendments to Subpart Y.  The comment
summaries are grouped by topic in two sections.  Section 2 presents
responses to the comments received by EPA on the original April 28,
2008, Subpart Y amendment proposal notice.  Section 3 presents responses
to the comments received by EPA on the May 27, 2009, supplemental
Subpart Y amendment proposal notice.

Table 1-1. List of Commenters on Amendments to 40 CFR 60 subpart Y
Proposed April 28, 2008 (73 FR 22901)

Docket No.

EPA-HQ-OAR-2008-0260	Date Received	Commenter Name and Affiliation

012 (see note a) 	May 15, 2008	Erin Chalmers

Associate Attorney

Sierra Club

Timothy Ballo

Associate Attorney

Earthjustice

Joe Lovett

Attorney

Appalachian Center for Law and the Environment

Cindy Rank

Mining Committee Chair

West Virginia Highlands Conservancy

Bill McCabe

Environmental Justice Organizer

Southern Appalachian Mountain Stewards

Vivian Stockman

Project Coordinator

Ohio Valley Environmental Coalition

Mary Anne Hitt

Executive Director

Appalachian Voices

013	May 20, 2008	Terry L. O’Clair, P.E.

Director

North Dakota Department of Health

Division of Air Quality

014 (see note b)	May 19, 2008	Quilla Earth Miralia, Esq.

Executive Director

Public Trust Environmental Legal Institute of Florida, Inc.

015 (see note c)	May 23, 2008	Anonymous Public Comment

016	June 2, 2008	Jeffrey Lieberman

Private citizen

018	June 12, 2008	Anna M. Schorr

Environmental Engineer

Corporate Office, Nucor Corporation

019	June 10, 2008	Tim W. Warden

President/CEO

Engart Dust Extraction Technology

A Division of Englo Incorporated

021	July 9, 2008	Sandi Tabor

General Counsel

Lignite Energy Council

022	July 11, 2008	Robert D. Bessette

President

Council of Industrial Boiler Owners (CIBO)

023 (see note b)	July 15, 2008	Anonymous Public Comment

024	July 14, 2008	Ronald W. Pircon

President and CEO

Benetech, Inc

025, 042 (see note d)	July 14, 2008	Stuart Sanderson

President

The Colorado Mining Association

026	July 14, 2008	Benjamin L. Brandes

Director of Air Quality

National Mining Association

027, 066 (see note d)	July 14, 2008	Christopher M. Hobson

Senior Vice President

Southern Company

028, 033	July 15, 2008	Linda Hilbert

Consumers Energy Company

029, 054, 067 (see note d)	July 14, 2008	Craig Eckberg

NRG Energy Inc.

030	July 14, 2008	Frank W. Rambo and Megan H. Berge

Baker Botts, LLP

on behalf of Class of ’85 Regulatory Response Group

031	July 11, 2008	Joseph D. Friedlander

Environmental Manager

The North American Coal Corporation

032, 065 (see note d)	July 10, 2008	Beth Goodnough

Director of Regulatory Affairs

Western Fuels-Wyoming, Inc.

034	July 14, 2008	Shawn Glacken

Senior Vice President, Environmental Services

Luminant Power (formerly TXU Power)

035, 059 (see note d)	July 14, 2008	F. William Brownell, Craig. S.
Harrison, and Lauren E. Freeman

Hunton & Williams LLP

on behalf of Utility Air Regulatory Group (UARG)

036	July 1, 2008	Beth Goodnough

Director of Regulatory Affairs

Western Fuels-Wyoming, Inc.

on behalf of Dry Fork Mine

037	July 10, 2008	David A. Finley

Administrator

State of Wyoming, Air Quality Division

038	July 11, 2008	Dean Metcalf

Director

Xcel Energy

039	July 11, 2008	William L. Boger

Environmental Manager

Foundation Coal West, Inc

040	July 14, 2008	Stephen F. Smith

Executive Director

Texas Mining and Reclamation Association

041	July 14, 2008	G. William Kalb

TraDet, Inc

043	July 15, 2008	Glen Warrington

President

Dust Solutions

044	July 14, 2008	Larry Volmer

Holland and Hart, LLP

on behalf of Newmont Mining Corporation and Newmont USA Limited

045	July 14, 2008	Andrew T. O’Hare

VP Regulatory Affairs

Portland Cement Association (PCA)

046	July 11, 2008	Gina Rau

Environmental Manager

Headwaters, Inc

047	July 14, 2008	Abbie S. Krebsbach,

Environmental Manager

Montana Dakota Utilities Co

048	July 14, 2008	Danny C. Cox

Director Engineering and Permitting

ICG, LLC

049	July 14, 2008	James C. Ashby

Manager, Environmental Affairs

Mettiki Coal, LLC

050	July 14, 2008	Ben Brandes

Director of Air Quality

National Mining Association

051	July 14, 2008	John R. Cline

Troutman Sanders LLP

on behalf of Peabody Energy Company

052	July 14, 2008	Ursula Kramer, Co-Chair (Tuscon, AZ)

Bob Hodanbosi, Co-Chair (Ohio)

National Association of Clean Air Agencies (NACAA)

053	July 14, 2008	Alice Edwards

Acting Directory, Air Quality Division

State of Alaska, Alaska Department of Environmental Conservation

055	July 14, 2008	William Scott

Modrall, Sperling, Roehl, Harris, and Sisk, PA

On behalf San Juan Coal Company and BHP Navajo Coal Company

056, 068 (see note d)	July 14, 2008	Erin Chalmers

Associate Attorney

Sierra Club

Timothy Ballo

Associate Attorney

Earthjustice

Joe Lovett

Attorney

Appalachian Center for Law and the Environment

Cindy Rank

Mining Committee Chair

West Virginia Highlands Conservancy

Bill McCabe

Environmental Justice Organizer

Southern Appalachian Mountain Stewards

Vivian Stockman

Project Coordinator

Ohio Valley Environmental Coalition

Mary Anne Hitt

Executive Director

Appalachian Voices

057	July 14, 2008	Mark G. Premo

Vice President

Chevron Mining Inc

058, 062 (see note d)	July 14, 2008	Monica Williams

Environmental Engineer

Thunder Basin Coal Company

060	July 14, 2008	Pamela F. Faggert,

Vice President and Chief Environmental Officer

Dominion Resources Services, Inc.

061	July 18, 2008	James A. (Jim) Murray

Private citizen

063	July 8, 2008	Christopher F. Blazek

Vice President Marketing

Benetech, Inc.

064 (see note e)	June 23, 2008 	Joe Murphy

Private citizen

069	July 22, 2008	Marion Loomis

Executive Director

Wyoming Mining Association

Notes:

a. Request for extension of public comment period.

b. Comment is not relevant to the proposed Subpart Y amendments.

c. Comment is incomplete

d. Duplicate copies of same comments entered in docket.

e. Comment was incorrectly posted to the wrong docket and is not
relevant to the proposed Subpart Y amendments.

Table 1-2. List of Commenters on Amendments to 40 CFR 60 subpart Y
Proposed May 27, 2009 (74 FR 25304)

Docket No.

EPA-HQ-OAR-2008-0260	Date Received	Commenter Name and Affiliation

082	May 28, 2009	K. Mathews

Private Citizen

084	June 26, 2009	Benjamin L. Brandes

Director, Air Quality

National Mining Association

085	July 10, 2009	James C. Ashby

Manager, Environmental Affairs

Mettiki Coal, LLC

086	July 13, 2009	Dennis R. Vaughn

Air Quality Specialist

San Juan Coal Company

Paul Nazaryk

Environmental Affairs Coordinator

BHP Navajo Coal Company

087	July 13, 2009	Christopher M. Hobson

Senior Vice President Research and Environmental Affairs

Southern Company

088	July 13, 2009	Phillip M. Gonet

President

Illinois Coal Association

089	July 13, 2009	Robert D. Bessette

President

Council of Industrial Boiler Owners (CIBO)

090	July 13, 2009	David Friedman

Director  Environmental Affairs

National Petrochemical and Refiners Association (NPRA)

091	July 13, 2009	Debra J. Jezouit and Megan H. Berge

Baker Botts, LLP

on behalf of Class of ’85 Regulatory Response Group

092	July 13, 2009	Tim Rust

Private Citizen

093	July 13, 2009	Andrew T. O’Hare

Vice President of Regulatory Affairs

Portland Cement Association (PCA)

094	July 13, 2009	Terry L. Steinert

Environmental Compliance Manager

Koch Carbon, LLC

095	July 13, 2009	Benjamin L. Brandes

Director, Air Quality

National Mining Association

096, 097 (Attachment), 125 (Attachment)	July 13, 2009	Peter Morgan

Sierra Club and Earthjustice

on behalf of Sierra Club, Southern Appalachian Mountain Stewards,
Appalachian Center for the Economy and the Environment, Ohio Valley
Environmental Coalition, and Appalachian Voices

098	July 13, 2009	Steve McMillen

Baker Botts LLP

on behalf of Oxbow Calcining LLC, Oxbow Midwest Calcining LLC, and Oxbow
Carbon and Minerals LLC

099, 132 (see note a)	July 13, 2009	F. William Brownell, Craig S.
Harrison, and Lauren E. Freeman

Hunton and Williams LLP

on behalf of Utility Air Regulatory Group (UARG)

100, 101 (Attachment), 102 (Attachment), 128 (see note a)	July 13, 2009
Vera Pardee

Center for Biological Diversity (CBD)

103	July 13, 2009	Lawrence W. Kavanagh

Vice President

Environment and Technology

American Iron and Steel Institute

Bruce A. Steiner

President

American Coke and Coal Chemicals Institute

104	July 13, 2009	Christopher G. Swanberg

Vice President

Environmental, Health, and Safety

CVR Energy, Incorporated

105	July 13, 2009	Matthew Todd

American Petroleum Institute (API)

106	July 13, 2009	Curtis D. Lesslie

Director of Environmental Affairs

Ash Grove Cement Company

107	July 13, 2009	Stuart Sanderson

President

The Colorado Mining Association

108	July 13, 2009	Beth Goodnough

Director Regulatory Affairs

Western Fuels—Wyoming, Incorporated

109	July 13, 2009	Pamela F. Faggert

Vice President and Chief Environmental Officer

Dominion Resources Services, Incorporated

110	July 13, 2009	Debra Nelson

Environmental Engineer

Great River Energy

111	July 13, 2009	Kathleen C. Antoine

Environmental Director

HOVENSA LLC

112	July 13, 2009	Bill K. Caylor

President

Kentucky Coal Association

113	July 13, 2009	Jeremy Nichols

Director, Climate and Energy Program

WildEarth Guardians

114	July 13, 2009	Richard Rosvold

Manager, Air Quality Environmental Services Department

Xcel Energy Services, Inc.

115	July 13, 2009	George Ellis

President

Pennsylvania Coal Association (PCA)

116	July 13, 2009	Donald McCloskey

Director, Environmental Strategy and Policy

PSEG Services Corporation

on behalf of PSEG Fossil LLC (PSEG Fossil)

117	July 13, 2009	Jessica A. Hall

Crowell and Moring LLP

on behalf of Peabody Energy Company

118	July 13, 2009	Charles Bennett

Environmental Support

Marathon Petroleum Company LLC (Marathon)

119	July 13, 2009	Michael G. Cashin

Senior Environmental Policy Advisor

Minnesota Power (MP) (Allete)

120	July 13, 2009	Farley R. Wood

Director, Environmental Compliance

Murray Energy Corporation

121	July 13, 2009	James A. Kiger

Environmental Manager

Oxbow Mining, LLC

122	July 13, 2009	Wendy S. Hutchinson

Regulatory Affairs Manager

Thunder Basin Coal Company (TBCC)

123	July 13, 2009	Craig S. Campbell

Vice President, Environment and Government Affairs

Lafarge North America Inc. (Lafarge)

124	July 13, 2009	Marion Loomis

Executive Director

Wyoming Mining Association (WMA)

126	July 13, 2009	David A. Finley

Administrator, Air Quality Division

Department of Environmental Quality (WYDEQ)

127	July 13, 2009	Stephen L. Rowland

Chief Operating Officer

Rain CII Carbon LLC

129 (see note b)	July 24, 2009	F. William Brownell, Craig S. Harrison,
and Lauren E. Freeman

Hunton and Williams LLP

on behalf of Utility Air Regulatory Group (UARG)

130	July 13, 2009	Roel A. Muñoz

Environmental Superintendent – Air Programs

Houston Refining LP

131b	August 5, 2009	Sherry L. Fisher

Environmental Policy Advisor

Hunton and Williams LLP

Notes:

a. Duplicate copies of same comment entered in the docket.

b. Comment received after comment period ended on July 13, 2009.

2.0  APRIL 28, 2008   SUBPART Y AMENDMENT PROPOSAL

2.1	Decision to Amend Subpart Y

2.1.1	Adequacy of Information Collected for Rulemaking

Comment:  One commenter (019) stated that EPA should reconsider amending
Subpart Y until EPA has a more detailed understanding of the newer
technologies that are currently available to control emissions from coal
preparation plants.  EPA should look forward to the newer innovative
technologies and strive to improve the position of the United States
(U.S.) in its environmental awareness and control techniques to further
reduce the airborne coal dust emissions.  The commenter described
enclosures vented to fabric filters as an “old and outdated
technology” and indicated that basing standards on the use of this
technology is not in the best interest of the citizens of the U.S.,
especially where the environment is concerned.

Response:  Section 111(b)(1)(B) of the Clean Air Act (CAA) provides that
the Administrator shall, at least every 8 years, review and, if
appropriate, revise the NSPS promulgated for a given source category
following the procedures required under section 111.  To meet this
legislative directive, EPA reviewed the existing NSPS for coal
preparation and processing plants in 40 CFR 60 subpart Y, determined
that amendments to the rule were appropriate, and published a proposal
notice on April 28, 2008 (see 73 FR 22901).  In response to comments on
that original proposal of Subpart Y amendments, EPA obtained additional
information about coal dryer emission control devices and demonstrated
control technologies used for reducing fugitive coal dust emissions from
various coal-handling operations.  This information included more
information about the performance and safety of using enclosures vented
to fabric filters to control fugitive coal dust emissions, and
information about newer control technology applications to coal
preparation and processing plants such as fogging systems and passive
enclosure containment systems (PECS).  Based on this additional
information, on May 27, 2009, EPA published a supplemental proposal
notice (see 74 FR 25305 and Section 3 of this document) and solicited
public comment on revised amendments to Subpart Y.  Because more than 8
years have passed since EPA last reviewed the Subpart Y standards, there
is no justification for delaying this review of Subpart Y or the
revisions to Subpart Y that this review has demonstrated are
appropriate.

2.1.2	Adequacy of Best Demonstrated Technology (BDT) Analysis

Comment:  Five comments were received (026, 032, 040, 042, and 044)
stating reasons the commenters believe that EPA’s determination of BDT
used to develop the proposed Subpart Y amendments was inadequate.
First, EPA’s process for determining BDT, as required by CAA section
111, was an abbreviated analysis that failed to follow the fundamental
statutory requirements for making such determinations.  To compensate
for limited emissions test data and related information specific to coal
preparation facilities, EPA assumed, without the requisite
demonstration, that its alternative data and information were
representative of the coal preparation industry throughout the nation.
EPA proposed standards of performance without the substantive support
necessary to justify those limitations and whether such limitations
could be achieved at affected facilities on a consistent basis.  Given
the analytical flaws and data deficiencies which characterize this
rulemaking, before finalizing any amendments to Subpart Y EPA must: (1)
consider all “adequately demonstrated technologies” and their
respective levels of “achievable” emissions; (2) determine those
“achievable” levels with emissions information that is demonstrated
to be “representative” throughout the coal preparation industry; and
(3) determine BDT with due consideration of the statutory factors.
Commenters stated that a standard of performance is not the maximum
degree of emission reduction technologically achievable.

Response:  EPA published a supplemental proposal on May 27, 2009, which
differs in several respects from the April 28, 2008, proposal addressed
by this comment.  Among other things, the supplemental proposal includes
a revised BDT analysis for coal processing, conveying, storage and
transfer systems.  It also differs from the original proposal in that it
did not propose to require that owners and operators of affected
facilities use a specific control technology (e.g., an enclosure vented
to a fabric filter or a chemical suppressant) to reduce fugitive
emissions from processing, conveying, storage and transfer systems (see
74 FR 25305).  Comments on the supplemental proposal are addressed in
Section 3 of this document.  The amendments to Subpart Y proposed in the
supplemental proposal are based on a proposed determination that any of
four technologies, including fogging systems and PECS, are adequately
demonstrated technologies that may constitute BDT for coal processing,
conveying, and storage and transfer systems.  The degree of emission
limitation achievable through application of each of these control
technologies was determined using test data and other information
specific to use of the control technologies at existing coal preparation
and processing plants.  The process used by EPA to identify BDT is
explained in the May 27, 2009, supplemental proposal.  This process and
the resulting determinations are consistent with the statutory
requirements of CAA section 111.

2.2	Subpart Y Applicability

2.2.1	Coal Preparation Plant Definition

Comment:  One commenter (016) requested that EPA consider amending the
definition of “coal preparation plant” to clarify EPA’s intention
to apply Subpart Y to coal preparation plants located at any type of
industrial site that meet the applicability criteria specified in the
rule (definition of coal preparation plant, construction/modification
date, and throughput threshold).  The commenter suggested using the
following definition, “Coal preparation plant means any facility
(excluding underground mining operations) which prepares coal by one or
more of the following processes: breaking, crushing, screening, wet or
dry cleaning, and thermal drying including, but not limited to,
facilities found at the following locations: at aboveground coal mining
operations, at coal processing operations and at end users of coal at
industrial sites” (Revision to existing definition suggested by
commenter shown in italics).

Response:  Entities potentially subject to Subpart Y include aboveground
coal breaking, crushing, screening, wet or dry cleaning, and thermal
drying at coal mine sites as well as industrial sites at which any of
these coal processes are conducted.  Applicability of Subpart Y to these
entities depends on the process coal throughput and the date of process
construction, reconstruction, or modification. EPA reviewed the existing
Subpart Y definition for the term “coal preparation plant” and
decided to revise the title of the term to be “coal preparation and
processing plant,” but not to change the definition of the term.  The
existing Subpart Y definition has been properly interpreted to apply the
rule to both the mine and industrial sites intended by EPA to be subject
to the rule.  As explained in the response to comment 3.8.1, the
affected facilities covered by subpart Y since its 1976 promulgation
have included both preparation and processing units, and the proposed
title change was for clarification purposes (i.e., to more accurately
reflect the affected facilities subject to subpart Y).  The final action
promulgates the proposed title change “Standards of Performance for
Coal Preparation and Processing Plants.”

2.2.2	Coal Preparation Plant Threshold Throughput

Comment:  One commenter (052) supports lowering the applicability of the
rule to facilities that process 100 or more tons per day (ton/day), the
approximate amount of coal that is transported by one rail car.  The
commenter stated that the documents in the docket for this rulemaking
indicate that EPA’s draft proposal initially had requested comment on
a lowered applicability threshold, but that the Office of Management and
Budget (OMB) requested that it be deleted.  The commenter believes that
100 ton/day is a significant quantity of coal and that there is no
reason that such an amount should not be subject to regulation under the
rule for the benefit of public health and the environment.

Response:  As with all regulations developed by the Agency, the April
2008 proposed rulemaking was subject to OMB review as part of the
statutory process.  At that time, EPA decided to maintain the
applicability threshold at 181 Mg/day (200 ton/day).  This applicability
threshold was established in the final rule (41 FR 2232; January 15,
1976).  In the supporting documentation, EPA explained that this
threshold effectuated EPA’s intent to control coal preparation sources
that are significant with respect to emissions (and, thus, comply with
the CAA section 111(b)(1)(A) mandate that the categories of sources for
which standards were to be developed were to be those which “…cause,
or contributes significantly to, air pollution which may reasonably be
anticipated to endanger public health or welfare”).   EPA does not
have any information that facilities of the size noted by the commenter
(i.e., 100 ton/day) would utilize the equipment necessary to classify
them as “coal preparation and processing plants” (e.g., coal
breaking, crushing, screening, wet or dry cleaning, and thermal drying),
and, thus, is not changing the applicability threshold at this time.
However, EPA will continue to assess the issue.

Comment:  One commenter (016) requested that EPA clarify whether the
throughput threshold of 181 Mg (200 tons) per day used to determine
applicability of a coal preparation plant to Subpart Y is a potential
maximum daily processing capacity, an average daily processing capacity
or some other equivalent definable term.

Response:  The Subpart Y applicability throughput threshold of 181 Mg
(200 tons) of coal processed per day is determined based on the rated
processing capacity of plant machinery used to break, crush, screen,
clean, or dry coal.  The equipment coal processing rating is to be
calculated assuming that the machinery is operated 24 hours per day.  An
owner or operator of a coal preparation and processing plant is subject
to Subpart Y if any one piece of equipment processing coal at the
facility site has the capacity to break, crush, screen, clean, or dry
coal at a rate greater than 181 Mg (200 tons) per day assuming 24
hours-per-day operation.

2.2.3	Subpart Y Amendments Applicability Date

Comment:  One commenter (039) stated that EPA should consider changing
the “effective date” of a rulemaking to the date of promulgation of
the final rule.  Retroactively applying the new rule to facilities that
began construction, reconstruction, or modification after the date the
rule was proposed jeopardizes and stymies any work that was in progress
at the time of the proposed ruling as well as work planned in the near
future.

Response:  The intent of the comment applies to the “applicability
date” for the Subpart Y amendments rather than the “effective
date.”  The “applicability date” is the date used to determine
which new, reconstructed, or modified sources in a given source category
are subject to the NSPS for that source category, and is established by
a statutory directive in CAA section 111(a)(2) that EPA does not have
authority to alter.  The definition of “new source” in CAA section
111(a)(2) requires that an NSPS apply to all sources constructed or
modified after the publication of proposed regulations.  Only affected
facilities that are constructed, reconstructed, or modified after April
28, 2008, or May 27, 2009, (the date varies depending on which proposal
addressed/revised a specific rule requirement) are subject to the new
requirements added to Subpart Y.  These dates reflect the dates that the
proposal and supplemental proposal were published in the Federal
Register (see 73 FR 22901 and 74 FR 25304).  The “effective date” is
the date used to establish the calendar dates by which the owner or
operator of an affected facility must comply with specific rule
requirements.  The effective date will be established by the date that
the final Subpart Y amendments are published in the Federal Register,
this date is not retroactive.

2.3	Subpart Y Thermal Dryer Standards

2.3.1	Thermal Dryers Processing Non-Bituminous Coals

Comment:  Two commenters (041 and 056) requested that EPA revise the
existing Subpart Y definition of “thermal dryer” used to determine
the affected sources subject to the rule’s control requirements.
Commenter 056 requested that EPA expand the existing definition of
“thermal dryer” to include equipment that processes non-bituminous
coal.  The commenter stated that there are existing thermal dryers
processing non-bituminous coals and that new thermal dryers processing
these coals may be built in the future.  The commenter cited several
examples of existing applications using thermal dryers to process
low-rank coals.  Commenter 041 presented background information on the
types and application of thermal dryers used for coal preparation in the
U.S.  The commenter requested that EPA specifically define the types of
thermal dryers subject to Subpart Y control requirements.

Response:  The existing Subpart Y definition of “thermal dryer”
limits the applicability of the rule’s control requirements to those
thermal dryers processing bituminous coals.  The proposed amendments to
Subpart Y published in the May 27, 2009, supplemental proposal notice
proposed to revise the definition of “thermal dryer” to expand the
applicability of the Subpart Y control requirements to direct contact
and indirect thermal dryers drying all coal ranks constructed,
reconstructed, or modified after May 27, 2009 (see 74 FR 25308-25309 and
Section 3 of this document).  For thermal dryers that were constructed,
reconstructed, or modified on or before May 27, 2009, the existing
Subpart Y definition for “thermal dryer” would still apply.

2.3.2	Thermal Dryer BDT Determination

<IP_ADDRESS>	Consideration of Alternative Coal Drying Technologies as BDT

Comment:  Two comments (035 and 056) were received regarding use of
alternative coal drying processes as related to EPA’s BDT
determination for coal dryers.  Commenter 056 stated that EPA provided
no factual or legal justification for including standards based on
emissions from direct thermal dryers when alternative indirect thermal
dryers produce lower emissions and are more cost-effective.  The
proposed performance standards based on existing controls for direct
thermal dryers do not reflect BDT.  The determination of BDT for thermal
dryers needs to include processes or technologies which are inherently
lower polluting.  Direct thermal dryers are an outdated method for
lowering the moisture content of coal because the process is expensive
and energy intensive, and a significant proportion of thermally-dried
fines can be lost as wind-borne dust.  Direct thermal drying is
typically now only used to reduce the cost of transport of moisture over
long distances and to avoid handling problems associated with excessive
moisture which will freeze in cold climates.  Indirect thermal dryers
use waste heat from other processes and have lower emissions than direct
thermal dryers.  Also, new coal preparation plants can use
centrifugal-type mechanical dryers which require no combustion-generated
heat and are less expensive than thermal dryers.  Additional options for
dewatering fine coal portions and tailings include the addition of
thickeners, flocculants, coagulants, and other chemical additives, along
with the use of press, vacuum, and other filters.  Commenter 035 stated
that thermal dryer designs are being considered in at least one pending
power plant permit application where waste heat from the process could
be used to partially dry the lignite before combustion, increasing
efficiency and slightly reducing CO2 emissions.  Thermal dryers may be
used at other locations in the future for low-rank coal applications.

Response:  As described in greater detail in the response to comments in
Section 3, EPA did consider alternative technologies in its BDT analysis
for the 2009 supplemental proposal, recognizing for example that either
recirculation or indirect thermal dryers may be available for use at new
facilities.  Further, in support of the final rule, EPA concluded that
recirculation or indirect thermal dryers also may be available for use
at reconstructed facilities.  Although alternative coal drying
technologies such as those noted by the commenters may inherently
produce lower air pollutant emissions compared to direct contact
once-through thermal drying, these alternative technologies to using a
direct contact once-through thermal dryer may not be technically
applicable, cost-effective, or the most energy efficient for all
possible coal drying applications that could be subject to Subpart Y.
The type of coal drying technology used at a given facility is
influenced by a variety of factors, including type of facility, coal
moisture reduction requirements, availability of waste heat sources at
the coal processing location, and drying process energy requirements
including electrical power consumption.  There are two basic types of
moisture in coal, free and inherent.  Mechanical drying techniques
(centrifuge, vacuum, compression, etc.) and chemical additives can
remove free moisture adsorbed onto the surface of the coal particles and
a portion of the hydroscopic moisture contained by capillary action
within microfractures in the coal particles, but are ineffective at
removing inherent moisture (and, thus, would only be applicable at
preparation plants utilizing coal washing).  Some type of thermal energy
is required to remove the interstitial and molecular (inherent) moisture
from the coal for applications where extremely low moisture content is
desirable.  Therefore, mechanical drying techniques are not suitable
replacements for thermal dryers under all circumstances, and because
waste heat is not available at all locations, thermal dryers using waste
heat are not a technically possible substitute for thermal dryers in all
situations.

<IP_ADDRESS>	Consideration of Add-on Particulate Matter (PM) Emissions
Control Technologies as BDT

Comment:  Three comments (035, 041, and 045) were received regarding
EPA’s determination that fabric filters are BDT for coal dryers.
Commenter 035 stated that fabric filters are BDT for a thermal dryer
used at a coal-fired power plant.  Centrifugal collectors (cyclones) and
venturi scrubbers consume an “extraordinary” amount of auxiliary
power and would probably not be installed at a coal-fired power plant.
Commenter 041 stated that fabric filters are not practical controls for
use on fluidized-bed thermal coal dryers processing eastern U.S. coals
because of operational and safety considerations.  Depending on the
specific thermal dryer operation, the fabric filter could be subject to
plugging due to dew point considerations.  The most significant issue is
that the high 17 to 18 percent oxygen content in the dryer exhaust gas
combined with the ultra-fine coal makes the fabric filters subject to
fires.  Commenter 045 stated that fabric filters do not constitute BDT
for thermal dryers at bituminous coal processing plants.  Emissions from
bituminous coal thermal dryers are sufficiently different from dryers
used at mineral production facilities and EPA cannot simply assume that
the technology is applicable to coal processing plants.

Response:  Coal-fired direct contact once-through thermal dryers
represent the majority of existing thermal dryers used at coal
preparation and processing plants, and most of those dryers use wet
scrubbers to control PM emissions.  However, no such new dryers have
been built in the last decade.  Possible replacement technologies for
direct contact once-through thermal dryers include indirect thermal
dryers and recirculation thermal dryers.  In addition, in some
circumstances, mechanical dryers may be used (however, as explained
above these are not suitable for all applications).  Because these
replacement technologies are available and because no new direct contact
once-thermal dryers have been built in recent years, EPA’s BDT
analysis for the 2009 supplemental proposal concluded that the control
technology and emissions rates from the best-performing existing
coal-fired thermal dryers do not necessarily represent BDT for a new
thermal dryer.  EPA believes that new thermal dryers could be designed
as either a coal-fired recirculation thermal dryer or an indirect
thermal dryer.  EPA concluded that the best adequately demonstrated
technology for controlling PM emissions from these types of dryers is a
fabric filter.  The Amax Coal Company’s Belle Ayr subbituminous coal
mine in Wyoming uses a recirculation thermal dryer equipped with a
fabric filter.  One indirect thermal dryer recently installed to dry
lignite at the Great River Energy Coal Creek Power Plant in North Dakota
uses a fabric filter.  The application of fabric filters to control PM
emissions at these facilities demonstrates that fabric filters can
safely be used for controlling PM emissions from the types of new
thermal dryers most likely to be built for coal processing at facilities
in the U.S.  For these and other reasons explained in the proposal and
supplemental proposal, EPA determined that BDT for new coal thermal
dryers is a coal-fired recirculation thermal dryer with a fabric filter
or an indirect thermal dryer with a fabric filter.

It is important to note that although EPA determined that coal-fired
recirculation thermal dryers with fabric filters or indirect thermal
dryers with fabric filters are BDT for new thermal dryers, the proposed
amendments to Subpart Y published in the May 27, 2009, supplemental
proposal notice (see 74 FR 25309 and Section 3 of this document) do not
require the use of a particular control technology.  EPA’s analysis
concluded that a new thermal coal dryer could use a once-through dryer
design and achieve the proposed PM emission limit using a high-energy
wet scrubber to control PM emissions.  High-energy wet scrubbers can be
designed and operated to control PM emissions from thermal dryers to
equivalent levels achieved by fabric filters.  Thus, the PM standards
for new thermal dryers established based on the determination that
coal-fired recirculation thermal dryers with fabric filters or indirect
thermal dryers with fabric filters are BDT, would not prohibit a new
coal preparation plant from choosing to build a new direct contact
once-through thermal dryer.  In the May 27, 2009, supplemental proposal
notice, EPA determined that PM limits for modified and reconstructed
thermal dryers should be based on direct contact once-through thermal
dryers with high-energy wet scrubbers.  However, as explained in EPA’s
response to the previous comment and to comment <IP_ADDRESS>, EPA has since
determined that thermal dryers undergoing reconstruction could undergo
the conversions necessary to meet the emission limits based on BDT for
PM emissions for new thermal dryers and, thus, meet the PM and opacity
limits of new facilities.  The final rule reflects this decision.

2.3.4	Thermal Dryer PM Emissions Limits

<IP_ADDRESS>	Promulgation of PM Emission Limits Based on Fabric Filters as
BDT

Comment:  Two commenters (039 and 045) stated that EPA’s suggestion in
the preamble for the proposed Subpart Y amendments that the Agency could
directly promulgate emission standards for thermal dryers based on using
fabric filters as BDT without formal re-proposal to allow for additional
public comment is inconsistent with the CAA and with judicial
interpretations of EPA rulemaking authority under CAA section 111, such
as Portland Cement Ass’n v. Ruckelshaus.

Response:  Proposed amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice included a PM emissions limit for new
thermal dryers (i.e., those constructed after April 28, 2008) based on a
determination that BDT is a fabric filter-controlled coal-fired
recirculation thermal dryer or a fabric filter-controlled indirect
thermal dryer.  In that supplemental proposal, EPA also determined that
PM limits for modified and reconstructed thermal dryers should be based
on direct contact once-through thermal dryers with high-energy wet
scrubbers.  Thus, through the supplemental proposal, EPA did allow for
additional public comment consistent with the CAA (see 74 FR 25309 and
Section 3 of this document).

<IP_ADDRESS>	Establish Separate Emissions Limits for PM2.5, PM10, and
Condensible PM

Comment:  Two commenters (052 and 056) disagreed with EPA’s decision
not to establish separate PM emission limits for condensible PM, PM2.5,
or PM10 emissions from thermal dryers.  Commenter 056 stated that PM
from thermal dryers includes products of combustion.  Combustion gases
contain significant proportions of fine PM, including PM10, PM2.5, and
condensible PM.  EPA has recognized that these are individual pollutants
with unique characteristics, health risks, and control technologies.
Because PM emissions from thermal dryers contain PM10, PM2.5, and
condensable PM, and these represent individually determined hazards,
separate emission standards for each of these PM fractions should be
set.  Commenter 052 recommended that EPA amend Subpart Y promptly at a
future date once test methods are available for measuring condensible PM
emissions from thermal dryers and other coal preparation processes.

as measured in micrometers (μ).  The first PM category is PM with an
aerodynamic diameter less than or equal to a nominal 10 μ and is
referred to as PM10.  The second PM category is PM with an aerodynamic
diameter less than or equal to a nominal 2.5 μ and is referred to as
PM2.5.  Depending on the composition of an exhaust gas stream from a
process, the PM emitted into the atmosphere can consist of a filterable
PM (FPM) fraction and a condensible PM (CPM) fraction.  The FPM fraction
is composed of solids of varying particle sizes determined by
source-specific characteristics (e.g., process type and operating
conditions, process input material compositions and properties, and
process chemistry).  The CPM fraction remains in a gaseous form in the
process exhaust stream until it is released into ambient air where it
condenses to a solid or liquid form when exposed to atmospheric
conditions.

The available PM emissions data for thermal dryers collected by EPA were
measured using EPA Method 5 (see 40 CFR part 60, appendix A-3).  For
this method, solid FPM is collected isokinetically on a filter media
(typically glass or quartz fiber) and is then measured gravimetrically
to determine FPM emissions.  Method 5 uses a probe and out-of-stack
filter, both heated to 248±25°F, to prevent condensation of moisture
and gaseous compounds.  This method, when performed correctly, provides
an accurate measurement of total FPM (for PM > 0.3 μ), but does not
measure FPM emissions by particle size distribution (i.e., PM10 or
PM2.5) nor does the method measure CPM.

EPA is revising existing test methods, EPA Method 201A—Determination
of PM10 Emissions (Constant Sampling Rate Procedure) and EPA Method
202—Determination of Condensible Particulate Emissions from Stationary
Sources, to provide test methods that will accurately measure PM10,
PM2.5, and CPM from stationary sources such as coal thermal dryers.
Amendments to these test methods were proposed on March 26, 2009 (74 FR
12970).  The amendments to Method 201A add a particle-sizing device to
allow for sampling of PM2.5, PM10, or both PM10 and PM2.5.  The
amendments to Method 202 revise the sample collection and recovery
procedures of the method to provide for more accurate and precise
measurement of CPM.  Until such time that Methods 201A and 202 are
finalized and sufficient test data using these methods can be collected
for coal thermal dryers, a determination of the need to add separate PM
emission limits to Subpart Y for PM2.5, PM10, or CPM emissions from coal
thermal dryers cannot be made.

<IP_ADDRESS>	Selection of Proposed Emission Limit Value

Comment:  One commenter (056) stated that the level of the PM emissions
limits for thermal dryers must be more stringent.  The commenter stated
that EPA appears not to have thoroughly reviewed the existing test data,
instead limiting its search to those facilities subject to stringent PM
permit limits.  EPA omitted from consideration the Hawthorne plant test
data which reported PM emissions of 0.0092 grains per dry standard cubic
foot (gr/dscf), which are less than half of the proposed limit.  The
most stringent permitted limits are not automatically correlated with
the lowest emission rates, and EPA must review a wider range of data
when developing the final limit for PM from direct thermal dryers.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice included a PM emissions limit for new
thermal dryers (i.e., those constructed after April 28, 2008) based on a
determination that BDT is a fabric filter-controlled coal-fired
recirculation thermal dryer or a fabric filter-controlled indirect
thermal dryer.  The PM emissions limit proposed for new thermal dryers
was based on performance test data and air permit limits specific to
existing coal thermal dryers with fabric filters (see 74 FR 25309 and
Section 3 of this document).  In the May 27, 2009, supplemental proposal
notice, EPA also determined that PM limits for modified and
reconstructed thermal dryers should be based on direct contact
once-through thermal dryers with high-energy wet scrubbers.  However, as
previously explained, EPA has since determined that thermal dryers
undergoing reconstruction could undergo the conversions necessary to
meet the emission limits based on BDT for PM emissions for new thermal
dryers (see Section 3 of this document).

<IP_ADDRESS>	Continuous Achievability of Proposed Emission Limit Value

Comment:  Two commenters (041 and 045) stated that EPA’s analysis of
the PM emissions data does not support the continuous achievability of
the proposed emission limit value by all potentially affected thermal
dryers.  Commenter 45 stated that EPA is required by Nat’l. Lime
Ass’n. v. EPA, 627 F.2d 416, 431 (D.C. Cir. 1980) to set a PM
emissions limit level that assures continuous compliance despite process
and control equipment variability and anticipated deterioration in
performance between regularly scheduled maintenance events.  The
commenter stated that EPA has recognized this condition for other
rulemakings, including in setting emission standards for hazardous air
pollutants at new cement kilns burning hazardous waste in 40 CFR part 63
subpart EEE.  Commenter 41 stated that the PM emissions data used for
selection of the PM emissions level must address the following factors:
(1) use of a BDT control configuration that includes both the high
energy scrubber and the mist eliminator; (2) operation of the high
energy scrubbers at less than 100 percent load; (3) the owner/operator
burden of more frequent performance testing that would be required for
the proposed emissions limit by existing State regulations (the
commenter specifically cited an example for the State of West Virginia);
and (4) PM emissions from coal thermal dryers are a function of heat
input and evaporative load, and not coal tonnage throughput.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice included PM emissions limits for
thermal dryers constructed, reconstructed, or modified after April 28,
2008.  Although the PM emissions limit for new thermal dryers is based
on a determination that BDT is a fabric filter-controlled coal-fired
recirculation thermal dryer or a fabric filter-controlled indirect
thermal dryer, the proposed level of PM control would be achievable
using wet control approaches (see 74 FR 25309 and Section 3 of this
document).  Further, EPA has data from two facilities, including 2
year’s of testing on one fabric filter-controlled unit, indicating
that the proposed emission limit is achievable.  EPA believes that other
factors noted by the commenter have been addressed through the use of a
concentration limit format and through the use of different emission
limit requirements for new and modified sources.  EPA also believes that
the performance testing requirements are appropriate.

<IP_ADDRESS>	Modified and Reconstructed Sources

Comment:  One commenter (041) stated that the proposed PM emissions
limit of 0.020 gr/dscf will eliminate the modification/reconstruction of
some existing thermal coal dryers for which it is practical to lower PM
emissions further but not to the level required by the proposed limit.
The commenter stated that in these cases the proposed PM emission limit
would be burdensome and counter-productive.  In contrast, a second
commenter (056) stated that the level of the PM emissions limit for
modified sources must be more stringent than the level proposed.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice revised the PM emissions limits for
thermal dryers and established separate limits for reconstructed and
modified thermal dryers (see 74 FR 25309 and Section 3 of this
document).  As previously explained, EPA has since determined that
thermal dryers undergoing reconstruction could undergo the conversions
necessary to meet the emission limits based on BDT for PM emissions for
new thermal dryers. (see Section 3 of this document).

2.3.5	Thermal Dryer Opacity Limit

Comment:  Four comments (045, 056, 041, and 052) were received related
to EPA’s decision not to revise the existing thermal dryer opacity
limit of 20 percent.  Commenter 045 agrees with EPA’s decision not to
revise the opacity limit for thermal dryers.  Commenter 056 disagrees
with EPA’s conclusion that the existing thermal dryer opacity limit of
20 percent is appropriate.  The commenter stated that there is, at best,
a tenuous correlation between opacity and PM emissions  The use of a
single source test by EPA cannot be taken as assurance that a
20 percent opacity limit will always, or even the majority of the time,
indicate PM emissions at or below the standard.  More appropriate
approaches include a thorough review of existing opacity test data from
thermal dryers, and lowering the opacity limit proportional to the
lowering of the PM limit (equivalent to approximately 13 percent
opacity, or 15 percent rounding up to the nearest 5 percent increment).
Commenter 041 stated that opacity measurements do not account for the
emissions of particulate-laden entrained droplets from wet scrubbers and
that these droplets contain between 15 to 55 percent of the total PM
emissions.  Commenter 052 stated that the opacity limits for thermal
dryers (and pneumatic coal-cleaning equipment as well) should be
replaced with the requirement to use a PM continuous emission monitoring
system (CEMS).

Response:  Based on a review of additional opacity data for coal thermal
dryers following the original Subpart Y proposal, a revised opacity
limit of less than 10 percent for new thermal dryers constructed after
April 28, 2008, was included in the supplemental Subpart Y proposal (see
74 FR 25309 and Section 3 of this document).  The supplemental Subpart
Y proposal maintains the existing opacity limit of less than 20 percent
for thermal dryers reconstructed or modified after April 28, 2008.  As
previously explained, EPA has since determined that thermal dryers
undergoing reconstruction could undergo the conversions necessary to
meet the limits, including the less than 10 percent opacity limit, based
on BDT for PM emissions for new thermal dryers (see Section 3 of this
document).  Compliance with the PM and opacity standards are determined
separately and the standards are separately enforced.  Further, the PM
standard is established at a level which will result in the design,
installation and operation of BDT; the opacity standard is established
at a level which will require proper continuous operation and
maintenance (O&M) of such control systems on a day-to-day basis, but not
require a more efficient or more expensive control system.  In addition,
opacity is established as an independent enforceable standard.  Opacity
standards are a necessary supplement to the PM standards because stack
tests are expensive, take a long time to schedule, cannot be performed
frequently, and are not indicative of continued O&M. PM CEMS are
discussed in the response to comment 3.5.4.

2.3.6	Thermal Dryer SO2 and NOx Emissions Limits

Comment:  One commenter (056) stated that EPA must set standards of
performance for SO2 and NOx based on BDT that can control these
pollutants because thermal dryers emit quantities of SO2 and NOx that
cause or contribute significantly to air pollution which may reasonably
be anticipated to endanger public health or welfare.  The commenter
provided an estimate of SO2 and NOx emissions from coal thermal dryers.

Response:  Revised amendments to Subpart Y published in the May 27, 2009
supplemental proposal notice added emission standards to reduce SO2,
NOx, and CO emissions from thermal dryers (see 74 FR 25310-25312 and
Section 3 of this document).

2.3.7	Thermal Dryer Volatile Organic Compounds (VOC) Emissions Limit

Comment:  One commenter (056) stated that EPA must set standards of
performance for emissions of volatile organic compounds (VOC) from
thermal dryers because organic components from chemical additives
introduced during wet processes, including flotation, may be entrained
in the coal and volatilized during drying.  The commenter provided an
estimate of VOC emissions from coal thermal dryers.

Response:  VOC emitted from thermal dryers are a result of both
incomplete fuel combustion and volatile matter released from the coal
bed as it is heated and dried.  Good combustion practices limit the
formation of both CO and VOC by providing sufficient oxygen in the
combustion zone for complete combustion to occur.  Revised amendments to
Subpart Y published in the May 27, 2009, supplemental proposal notice
added emission standards to reduce CO emissions from thermal dryers
based on a determination that good combustion practices constitutes BDT
for CO emissions from thermal dryers (see 74 FR 25311 and Section 3 of
this document).  No technology for control of VOC emissions beyond
combustion controls was identified as being used by coal thermal dryers.
 However, by setting an emissions limit to control CO emissions, VOC
emissions that result from incomplete combustion are also reduced.  The
VOC emissions resulting from volatile matter released from the heated
coal bed itself are variable.  EPA concluded that a separate VOC
emission standard cannot be established that would be achievable for
variable coal ranks processed in thermal dryers across the country.
Therefore, EPA dids not propose under this action to amend Subpart Y to
include a separate VOC emission standard for thermal dryers.

2.3.8	Thermal Dryers with In-line Coal Mills

Comment:  One commenter (045) requested that EPA clarify the application
of the thermal dryer PM emissions limit to a thermal dryer used with an
in-line coal mill.  The commenter stated that it is not entirely clear
from the language of the proposed Subpart Y amendments whether the
exhaust gases from a bituminous coal thermal dryer that is part of an
in-line coal mill are considered to be “exhausted to the
atmosphere,” as required to meet the definition of “thermal
dryer.”  If a new or modified in-line coal mill were treated as both a
thermal dryer and as coal processing and conveying equipment, and if the
emissions from that in-line coal mill had to meet the lower PM emissions
limit of 0.005 gr/dscf applicable to coal processing and conveying
equipment–as opposed to the 0.020 gr/dscf limit for new and modified
thermal dryers–then the NSPS would not be based on BDT and the cost of
achieving 0.005 gr/dscf would be much greater, if the standard could be
achieved at all.  The commenter requested that such a configuration be
subject to the PM mass emission limits and opacity limits applicable to
thermal dryers rather than to coal processing and conveying equipment.

Response:  EPA agrees that in the case of a thermal dryer that is part
of an in-line coal mill at a Portland cement manufacturing facility
where all of the thermal input is supplied by cement kiln exhaust or
clinker cooler exhaust, the dryer should be regulated under the
appropriate Portland Cement kiln regulations (40 CFR Part 63 subpart LLL
and 40 CFR 60 subpart F).  Revised amendments to Subpart Y published in
the May 27, 2009, supplemental proposal notice made some additional
changes to the PM emissions limits for thermal dryers and for coal
processing and conveying equipment, coal storage systems, and coal
transfer system operations constructed, reconstructed, or modified after
April 28, 2008 (see 74 FR 25310-25311, 74 FR 25313-25314, and Section 3
of this document).  The final rule contains some further revisions.  The
amended emissions limits would be applicable to new, reconstructed, or
modified thermal dryers at Portland cement manufacturing facilities in
situations where the thermal input is not supplied by cement kiln or
clinker cooler exhaust.  Further discussion is provided in the response
to comment 3.3.8.

2.4	Subpart Y Coal Processing, Conveying, Storage and Transfer System
Standards

2.4.1	Affected Sources

<IP_ADDRESS>	Coal Processing and Conveying Equipment

Comment:  One commenter (035) stated that EPA’s proposal to revise the
definition of “coal processing and conveying equipment” by changing
the term “conveyor belts” to “conveying systems” should not be
made without explaining and soliciting comment on the significance of
the change.  Because the absence of a reference to “conveying
systems” in the rule was relevant to EPA’s prior applicability
determinations, this revision could have significant impacts.  The
commenter would support over-ruling the EPA’s prior applicability
determinations that focused on only a narrow part of a conveying system
rather than the entire system.

Response:  EPA intends to maintain the existing Subpart Y definition for
the term “coal processing and conveying equipment.”  The April 28,
2008 Subpart Y proposal and subsequent May 27, 2009 supplemental Subpart
Y proposal that included a definition for the term “coal processing
and conveying equipment” that substituted the words “conveying
systems” in place of “conveyor belts” was an error.  EPA intends
to maintain the existing definition for “coal processing and conveying
equipment” in which coal processing and conveying equipment means
“any machinery used to reduce the size of coal or to separate coal
from refuse, and the equipment used to convey coal to or remove coal and
refuse from the machinery.  This includes, but is not limited to,
breakers, crushers, screens, and conveyor belts.”

Comment:  Two commenters (025 and 040) requested that EPA clarify that
Subpart Y performance standards apply only to conveying equipment that
is an affected facility.  With the exception of a transfer and loading
system, other so-called “transfer points” to or from conveying
equipment should not be considered to be affected facilities at coal
preparation plants.

Response:  As discussed in the response to the preceding comment, EPA
intends to maintain the existing Subpart Y definition for the term
“coal processing and conveying equipment.”  The potential for coal
dust emissions to the atmosphere from machinery conveying coal exists
from openings other than those where the coal enters or exits the
machinery.  All potential fugitive coal dust emission points associated
with machinery that meet the definition of “coal processing and
conveying equipment” are subject to the applicable Subpart Y control
requirements.

<IP_ADDRESS>	Coal Unloading Activities

Comment:  Four commenters (026, 035, 039, and 040) stated that coal
unloading activities should not be subject to Subpart Y requirements.
Commenter 026 stated that the definition of transfer and loading as it
applies to Subpart Y is not well defined.  In contrast, Commenter 056
stated that EPA should require controls for unloading to plant machinery
and open piles.  Commenters 035 and 040 stated that EPA previously
issued an interpretation of Subpart Y (63 FR 53288-53290, October 5,
1998) that concluded that coal unloading, which involves conveying coal
to coal plant machinery, is subject to Subpart Y and that any fugitive
emissions from coal dumping must be included in a determination of
whether a coal preparation plant is a major source subject to Title V
permitting requirements.  The commenters stated that EPA has not
provided any data for the proposed Subpart Y amendments to justify
applying the rule’s control requirements to unloading activities.  The
commenters requested that EPA either provide a justification for
establishing standards for unloading activities, and allow for comment
on such justifications, or that EPA reverse this applicability
determination so that unloading activities are not subject to Subpart Y.
 Commenter 039 disagreed with EPA’s determination that truck dumps are
affected facilities subject to Subpart Y.  At the commenter’s
facility, trucks discharge coal through a grizzly (a steel grid plate)
into a hopper, neither of which is “conveying equipment.”  This
commenter stated that a piece of equipment should not be considered an
affected facility simply because conveying may take place further in the
process.

Response:  The unloading of coal from the trucks, railcars, or barges
used to deliver coal to a facility has the potential to generate
significant amounts of fugitive coal dust emissions to the atmosphere if
effective control measures are not implemented.  Thus, these activities
remain subject to Subpart Y requirements.  In addition, revised
amendments to Subpart Y published in the May 27, 2009, supplemental
proposal notice establish work practice standards to control fugitive
coal dust emissions from open storage piles, including the loading,
unloading, and conveying operations of open storage piles (see 74 FR
25312-25313 and Section 3 of this document).  EPA believes the
amendments made also address the issue of the clarity of the definition
of “transfer and loading.”  Further, EPA utilized data from coal
uploading operations in assessing the emission limit for coal unloading
operations in the Supplemental Proposal.

<IP_ADDRESS>	Coal Storage Piles

Comment:  Many comments were received on expanding the applicability of
Subpart Y to include open storage piles.  One commenter (056) stated
that EPA should expand the scope of “coal storage system to” include
open storage piles.  Open coal storage piles are a significant source of
PM emissions for which the commenter believes control technology is
available.  Wind erosion of open storage piles, which can be exacerbated
when heavy machinery is driven over the piles repeatedly, creates
significant amounts of PM emissions.  Potential control measures include
enclosures, wind fences, or other barriers, and wet or chemical
suppression.  Other commenters (021, 027, 029, 030, 031, 034, 035, 038,
and 044) stated that EPA should not expand the scope of “coal storage
system” to include open storage piles.  Commenters 027 and 035
supported retention of the existing definition of “coal storage
system” in Subpart Y and the case-by-case regulation of coal storage
piles.  Commenters 029, 030 and 038 stated that using the NSPS program
to regulate coal storage piles at coal-fired power plants would raise
the following regulatory issues: (1) the terms reconstruction and
modification are not technically relevant to open storage piles; (2)
demonstrating compliance with a PM or opacity limit on a coal pile would
be difficult: and (3) because the characteristics of coal, such as
moisture content and hardness, can vary significantly based on the
source, even within a given subclass, control techniques that work well
for coal from one mine may not work as effectively for coal from another
mine, making it difficult to assign a general control efficiency for any
particular control technique.  Commenters 021, 031, and 044 stated that
expanding coverage to include open storage piles is unnecessary and
would be inconsistent with EPA’s regulatory approach with other NSPS
source categories.  For example, for 40 CFR 60 subpart J for petroleum
refineries, open storage of petroleum coke is not considered to be an
affected source.  Petroleum coke has similar silt and related dusting
properties as forms of coal.  In addition, PM emission limitations and
work practice standards are effectively in place at the State level to
address open coal stockpiles on a site-specific basis to meet ambient
air quality standards. Redundant regulation on the Federal level is not
required.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice added work practice standards for
controlling fugitive coal dust emissions from open coal storage piles
(see 74 FR 25312-25313 and Section 3 of this document).

<IP_ADDRESS>	Plant Roads

Comment:  One commenter (056) stated that EPA must establish equipment
and work practice standards or performance standards based on silt
loading to control PM emissions from roads.  Potential work practice and
equipment standards include use of tire or truck wash systems, vacuum
sweeper trucks, and wet suppression and waste flushing.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice added work practice standards for
controlling fugitive coal dust emissions from on-site plant roadways
(see 74 FR 25312-25313 and Section 3 of this document).  However, as
explained in EPA’s response to comment <IP_ADDRESS>.1, EPA has since
determined that roads will not be added as affected facilities under
these Subpart Y amendments.

<IP_ADDRESS>	Coal Hauling Trucks and Railcars

Comment:  One commenter (056) stated that EPA should require controls
for trucks and trains in the form of covers.  Trucks, vehicles, and
trains are a large source of particulate emissions due to wind erosion.
EPA must regulate rail and truck transport as part of the coal
preparation plant standard because they are significant sources of
particulate emissions for which control technology is available.
Although rail cars and trucks themselves are not “stationary
sources” and likely could not be regulated under the NSPS as an
independent stationary source, it is the coal preparation plant that is
the stationary source, and train cars and trucks are simply one source
of emissions among many at this source.  Thus, rail and truck traffic
that operate at a coal preparation plant facility must be subject to
standards of performance.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice addressed the control of fugitive
coal dust emissions from open piles, including the loading, unloading,
and conveying operations of open storage piles by adding work practice
standards.  At this time, piles of coal that have been loaded into
trucks, railcars, and/or ships would not be subject to the fugitive dust
emissions control plan (see 74 FR 25312-25313 and Section 3 of this
document).

<IP_ADDRESS>	Coal Sampling Systems

Comment:  Two commenters (034 and 035) requested that coal sampling
systems located at coal preparation plants be specifically exempted from
Subpart Y.  These systems generate low emissions because the systems
typically are in enclosed structures, operate at low speeds and
throughputs, and operate intermittently.  Consequently, the cost of
implementing the proposed controls is unreasonably high.

Response:  Coal sampling systems at affected facilities have been
subject to the existing Subpart Y requirements since they were
originally promulgated in 1976.  Commenters have not provided specific
data demonstrating that the compliance costs associated with coal
sampling systems are unreasonably high.  In addition, EPA provided
alternatives to collection and control of the types of emissions sources
described by the commenters (e.g., conveyors, crushers) under the
revised amendments to Subpart Y published in the May 27, 2009,
supplemental proposal notice.  Also, an affected facility enclosed
within a building or structure would be considered to be in compliance
if the building in which it is enclosed is in compliance with the
standard.  For these reasons, EPA does not believe it would be
appropriate, in this review, to add the exemption requested by
commenters.

<IP_ADDRESS>	Coal Mine Portable Screens

Comment:  One commenter (034) requested that EPA provide an exemption
for portable screens used in non-bituminous coal surface coal mines.
These screens are used to remove non-coal material at the mine prior to
transport of the coal to a power plant.

Response:  EPA agrees that the operation noted by the commenter should
be considered part of the mining operation and not part of the coal
preparation process and, thus, not subject to Subpart Y (unless breaking
or crushing of the coal was to be done in the screens).  Clarification
has been made in the final rule.

2.4.2	Subcategorization of Standards by Coal Rank

<IP_ADDRESS>	Relationship of Coal Rank to Coal Dust Emissions Control

Comment:  One commenter (040) stated that the fundamental premise
underlying EPA’s proposed Subpart Y standards of performance is that
coal preparation facilities “handling” non-bituminous coals generate
larger amounts of uncontrolled PM emissions than do the same facilities
“handling” bituminous coal.  Implicit in that premise is the further
assumption that coal rank is a surrogate for the surface moisture
content of coal.  On that basis EPA has concluded that enclosures with
fabric filters are cost-effective and, therefore, represent BDT for
facilities handling non-bituminous coal, but conversely, chemical
suppression is more cost-effective for facilities “handling”
bituminous coal and, thus, constitutes BDT for that subcategory of coal
preparation.  However, although coal rank may be one “predictor” of
potential emissions, the uncontrolled emissions from coal preparation
facilities are influenced by a variety of different parameters,
including not only moisture and coal rank separately, but also other
coal characteristics such as silt and ash content, wind speed, climate,
and topography.  As a result, EPA’s generalization of the relationship
between coal rank and uncontrolled emissions is too inexact to
accurately quantify emissions from any particular coal preparation plant
for purposes of Subpart Y regulation.  Therefore, until EPA collects
sufficient emissions data from coal preparation facilities to better
define the levels of representative uncontrolled emissions for the
industry, the “rank neutral” standards of performance remain the
more appropriate approach for Subpart Y.  A second commenter (029)
stated that chemical dust suppression is equivalent to bag filter
systems, regardless of coal rank.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice eliminated separate fugitive dust
control requirements for coal processing, conveying, storage and
transfer systems depending on the coal rank processed (see 74 FR 25306
and Section 3 of this document).  The BDT used as the basis for
establishing the final standards for these affected sources is not based
on the coal rank processed.  The final rule allows affected owners and
operators to select from a range of control technologies (including, but
not limited to, enclosures with fabric filters, chemical suppressants,
fogging systems, and engineered flow transfer equipment) that they
determine is applicable and appropriate for controlling fugitive
emissions from the ranks of coal processed at their facilities.

<IP_ADDRESS>	Coal Rank Subcategorization Inconsistent with Existing Policy

Comment:  One commenter (044) stated that to require plants processing
non-bituminous coals to vent all emissions through a stack constitutes a
fundamental change from EPA’s long-standing policies regarding control
of fugitive emissions and would require a fundamental redesign of a
major segment of the coal preparation industry.  This goes beyond
EPA’s authority under CAA section 111, and requires not only
compliance with a standard, but also a specific configuration or
reconfiguration of control equipment.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice eliminated separate fugitive dust
control requirements for coal processing, conveying, storage and
transfer systems depending on the coal rank processed (see 74 FR
25306-25307 and Section 3 of this document).  Under the final rule,
owners and operators of affected facilities processing non-bituminous
coals are not required to use enclosures with fabric filters to control
fugitive emissions, and, instead, may select the fugitive emissions
control measures best suited to their site-specific conditions provided
that the selected controls meet the relevant rule requirements.

<IP_ADDRESS>	Anthracite Coal

Comment:  One commenter (018) stated that there is no justification for
classifying anthracite coal with subbituminous coals for purposes of
determining BDT for coal processing and conveying equipment, coal
storage system, and transfer and loading system PM and opacity limits.
It is not clear that anthracite coals, which are typically very hard,
share the same characteristics as softer subbituminous and lignite coals
for purposes of assessing the impact of wet suppression versus fabric
filter controls during the coal processing, conveying, storage, and
transfer and loading period.  Unlike lignite and similar lower rank
coals, anthracite’s heating value is unlikely to be significantly
affected by the use of water suppression.  Application of water and
chemical suppressants as BDT for bituminous coals is well supported.
Enclosure and venting to a fabric filter is not required for this rank
of coal.  This commenter agrees with the finding that bituminous coal PM
emissions are well controlled by water or chemical dust suppressants and
that the added control that may be achieved by full enclosure and
venting to a fabric filter is not warranted by the small improvement in
removal.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice eliminated separate fugitive dust
control requirements for coal processing, conveying, storage, and
transfer systems depending on the coal rank processed (see 74 FR
25306-25307 and Section 3 of this document).  The coal rank processed by
an affected facility, whether it be anthracite, bituminous,
subbituminous, or lignite, was not used for determining BDT to establish
the final standards applicable to coal processing and conveying
equipment, coal storage systems, and transfer and loading systems.

<IP_ADDRESS>	Blended Coals

Comment:  Several commenters (027, 029, and 035) stated concerns
regarding the application of the proposed amendments to affected
facilities at electric utility power plants handling blends of different
coal ranks.  Commenter 029 stated that the proposed regulation defines
non bituminous coal as any coal other than bituminous coal.  Under this
definition, facilities using blends of bituminous coal and
non-bituminous coals may be classified as non-bituminous coal.  Many
coal-fired electric utility power plants handle a variety of coal ranks
and in some cases blend the different rank coals depending on coal
supply market conditions.  It would be cost prohibitive to require the
modification of the fugitive dust controls for each coal rank.
Therefore, this commenter requests that EPA adopt the same requirements
for bituminous, non-bituminous, and blended coals.  Commenters 027 and
035 stated that different ranks of coal that are blended together often
are delivered to the power plant already blended, or are co-mingled in
blending operations soon after arriving at the power plant.  The
commenters suggested that EPA’s BDT determination for coal blends that
are primarily, rather than exclusively, bituminous coals on a tonnage
basis be enclosures and chemical suppression.  EPA has drawn a similar
line in other regulatory contexts for coal-fired utility power plants.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice eliminated separate fugitive dust
control requirements for coal processing, conveying, storage, and
transfer systems depending on the coal rank processed (see 74 FR
25306-25307 and Section 3 of this document).  Under the final rule, the
control requirements for affected facilities at an electric utility
power plant (or any other coal preparation and processing plant subject
to Subpart Y) are the same regardless of the coal rank processed,
including blends of different coal ranks.

<IP_ADDRESS>	Impact on Facility Fuel Flexibility

Comment:  One commenter (022) stated that Subpart Y should provide for a
more flexible definition of facilities using bituminous coal.  Because
the control requirements are more stringent for coal preparation plants
processing coals other than bituminous coal, it is possible that States
could write permits limiting plants to bituminous coal only and
interpret any change to subbituminous coal as a modification.
Conceivably, as little as one delivery of subbituminous coal could be
considered a modification.  The flexibility to utilize different coal
supplies is very important to minimize fuel costs, meet environmental
requirements, and deal with coal supply interruptions.  The rule as
drafted could greatly limit the fuel flexibility of plants.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice eliminated separate fugitive dust
control requirements for coal processing, conveying, storage, and
transfer systems depending on the coal rank processed (see 74 FR
25306-25307 and Section 3 of this document).  Under the final rule, the
control requirements for affected facilities processing bituminous coals
are the same as those for affected facilities processing coals other
than bituminous coal.  Therefore, the final Subpart Y amendments do not
impact flexibility of a facility to use different coal supplies.

2.4.3	BDT Determination

<IP_ADDRESS>	Equivalency of Fabric Filter and Chemical Suppression Control
Systems

Comment:  One commenter (054) stated that either venting to a fabric
filter or chemical dust suppression should be considered equivalent
fugitive coal dust controls.  Facilities should be given the option to
choose either chemical dust suppression or fabric filter systems.

Response:  EPA reconsidered the BDT determination used to establish
standards for coal processing, conveying, storage, and transfer systems.
 Revised amendments to Subpart Y published in the May 27, 2009,
supplemental proposal notice allow affected owners and operators to
select from a range of fugitive coal dust control technologies
(including, but not limited to, enclosures with fabric filters and
chemical suppressants) to control PM emissions from coal processing,
conveying, storage, and transfer system operations (see 74 FR
25313-25314 and Section 3 of this document).

<IP_ADDRESS>	Consideration of Alternative Coal Dust Control Technologies as
BDT

Comment:  Many comments were received (013, 021, 030, 031, 032, 035,
036, 039, 040, 043, 044, 051, 063, and 069) regarding the topic that
EPA’s BDT determination for coal processing, conveying, storage, and
transfer systems did not consider control technologies other than fabric
filters and chemical suppression that are demonstrated and commercially
being used to control PM emissions from coal handing operations.  The
other control technologies included fogging systems and engineered flow
transfer equipment, also termed passive enclosure containment system
(PECS).  The commenters presented multiple reasons to support their
determinations that the use of fogging systems or PECS should be
considered by EPA as BDT, and that those technologies are either
equivalent or superior in performance and cost-effectiveness to using
full enclosures vented to a fabric filter.  Commenter 069 stated that
the proposed amendments do not reflect current emission control measures
permitted as Best Available Control Technology (BACT) at coal
preparation plants in Wyoming, and that this will consequently have a
profound impact on the coal mining industry, the safety of mine
employees, and the State’s air quality program.  Commenters 013, 032,
040, and 044 stated that fogging systems and PECS presently are used for
coal preparation operations, and meet or exceed the performance of
fabric filter or chemical dust suppression emission controls.  Commenter
051 stated that wet suppression is more effective and cost-effective
than chemical suppression.  Commenter 032 stated that the Wyoming
Department of Environmental Quality (WDEQ) allows coal handling sources
to be permitted at 0 lb/hr of PM for areas controlled by fogging systems
or PECS.  Commenters 013 and 040) stated that PM emissions from fully
enclosed lignite conveying, crushing, and transfer equipment in North
Dakota are effectively controlled by water fogging systems.  The
performance of both fogging systems and PECS have proven to be superior
to fabric filters for dust control both within the working environment
(for Mine Safety and Health Administration [MSHA] rule compliance) and
outside the buildings (for EPA and WDEQ rule compliance).

Response:  EPA reconsidered the BDT determination used to establish
standards for coal processing, conveying, storage, and transfer systems.
 Based on review of public comments and subsequent analysis, EPA
concluded that enclosures with chemical suppression or vented to fabric
filters are not the only technology that is BDT for coal processing,
conveying, storage, and transfer systems.  Depending on
facility-specific factors, fabric filters, PECS, fogging systems, and
wet extraction scrubbers can effectively control PM emissions to
equivalent levels.  In addition, fogging systems, PECS, and wet
extraction systems often can be implemented at lower costs than fabric
filters.  Revised amendments to Subpart Y published in the May 27, 2009,
supplemental proposal notice eliminated requirements that owners and
operators of affected facilities must use a specific control technology
(e.g., an enclosure vented to a fabric filter or a chemical suppressant)
to reduce fugitive emissions from processing, conveying, storage, and
transfer systems (see 74 FR 25313-25314 and Section 3 of this document).
 The revised standards are based on a BDT determination based on the
level of reduction achievable by four technologies, which include
fogging systems and PECS.  The final rule allows affected owners and
operators to select from a range of fugitive coal dust control
technologies (including, but not limited to, enclosures with fabric
filters, chemical suppressants, fogging systems, PECS) best suited to
controlling PM emissions from the operations of coal processing,
conveying, storage, and transfer system configurations and operating
practices used at a given facility.

2.4.4	Fabric Filters (Baghouses)

<IP_ADDRESS>	Fabric Filter Safety

Comment:  Many commenters (019, 024, 030, 032, 036, 058, and 069) stated
that use of fabric filters at coal preparation plants is unsafe due to
the potential for coal fires and explosions.  Fabric filters must comply
with required MSHA safety standards due to their potential for fires
and/or explosions.  Subbituminous coal dust can spontaneously combust if
it accumulates for long periods of time, or if it is exposed to water or
oxygen.  Because fabric filters, by design, extract dust and eventually
suck it to a collection point where it is recycled back onto the belt,
fabric filters often have dust accumulations which do not purge from the
dust collection ductwork.  The fabric filters accumulate dust, moisture
eventually enters the ductwork and fabric filter proper, and the
collected coal dust can spontaneously combust and explode.  To avoid
this potential safety hazard, some coal processing plants are in the
process of or have switched from fabric filter dust control to newer
technologies that are available in the U.S. such as fogging and PECS for
dust control.  Commenter 34 stated that fabric filters do little to
reduce employee dust exposure.

Response:  Fabric filters with proper design, operation, and maintenance
are one technology available for controlling fugitive dust emissions at
coal preparation and processing plants. The revised amendments in the
May 27, 2009, supplemental proposal notice allow an owner or operator,
who prefers to do so, to use an alternative control technology rather
than using an enclosure vented to a fabric filter (see 74 FR 25313-25314
and Section 3 of this document).  EPA believes that this will provide
owners/operators with the necessary flexibility to address
plant-specific safety concerns.

<IP_ADDRESS>	Fabric Filter Performance

Comment:  Two commenters (032 and 036) stated that fabric filters are
ineffective at controlling dust on a consistent basis.  Examples cited
by commenters include comments that bag dust sometimes billows out of
the explosion vents, performing maintenance on fabric filters results in
uncontrolled releases of dust directly from the fabric filter into the
environment, bag replacement exposes the maintenance personnel to very
fine coal dust and emits large volumes of dust to the environment, and
bags freeze up in cold weather and break.

Response:  Properly designed, operated, and maintained fabric filters
can consistently achieve high levels of PM emissions control over long
periods of time . The problems cited by the commenters can readily be
avoided with appropriate fabric filter design features for the
site-specific conditions and facility personnel following standard good
operating and maintenance practices for fabric filters.

<IP_ADDRESS>	Fabric Filter Dust Disposal

Comment:  One commenter (019) stated that storage and re-handling of
collected dust by fabric filters requires the collected dust to be
re-deposited back into the material handling process.  This extremely
fine “float” dust increases airborne dust emissions “downstream”
which once again must be addressed.  This becomes very costly for the
operator and produces a negative impact to the environment.

Response:  Handling of the collected dust in the manner noted by the
commenter would be subject to the provisions of Subpart Y.

2.4.5	Conveyor System Enclosures

<IP_ADDRESS>	Enclosure Fugitive Dust Emission Points

Comment:  One commenter (038) stated that the primary fugitive emission
generation points for an enclosed conveyor system are at the drop points
rather than along the belt runs.  As such, the commenter stated that it
should be specified that, for systems that are enclosed, the emission
control and monitoring points for coal conveying systems should be
relegated to the drop points.

Response:  Emission control and monitoring requirements under Subpart Y
apply to all openings in an enclosed conveyor system where fugitive coal
dust emissions potentially can be released to the atmosphere.  However,
it is common for sources to monitor emissions only at transfer or drop
points on conveyer belts.

<IP_ADDRESS>	Enclosure Safety

Comment:  Two commenters (027 and 035) stated that an enclosure should
serve the purpose of providing a cavity for controlling PM, and an
enclosed conveyor is comprised of a conventional belt conveyor, equipped
with sideboards and a cover (typically a three-sided enclosure).  Each
side of the enclosure includes a “skirt” that minimizes and controls
the ingestion of ambient air and allows air infiltration.  The
commenters stated that safety and explosion concerns strongly caution
against completely enclosing conveyors handling non-bituminous coals.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice would not require that affected
sources be mechanically vented (see 74 FR 25313 and Section 3 of this
document).  Coal handling operations that are not mechanically vented
would be subject only to opacity standards.  Thus, conveyors handling
non-bituminous coals need not be completely enclosed to be in compliance
with Subpart Y.

2.4.6	PM Emission Limits

<IP_ADDRESS>	Applicability of PM Emission Limits

Comment:  Two commenters (021 and 031) stated that PM emissions from
fogging systems and PECS cannot be measured using EPA Method 5 and,
consequently, sources that use fogging systems and/or PECS should not be
subject to the PM grain loading standard.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice would establish a new PM emissions
limit that would apply only to affected sources that are mechanically
vented (see 74 FR 25313 and Section 3 of this document).  “Mechanical
vent” is defined to mean a vent using a powered mechanical drive
(machine) to induce air flow. PECS and fogging systems do not use a
powered machine to induce airflow and would not be subject to the PM
emissions limit.  For situations where these control technologies are
used, only the opacity standard would apply.

<IP_ADDRESS>	Fenceline Ambient Air Monitoring of Coal Preparation Facilities

Comment:  One commenter (052) stated that the PM size fractions used for
the NAAQS (PM2.5 and PM10) should be addressed by Subpart Y.  The
commenter requested that EPA consider fenceline ambient air monitoring
of coal preparation facilities to quantify PM2.5 and PM10 emissions as a
requirement under Subpart Y.

Response:  CAA section 111 requires new sources to meet emission
standards based on BDT. Fenceline ambient air monitoring to quantify
pollutant emissions levels would not ensure that BDT-based emission
standards are being met on each affected facility within the fenceline
(i.e., the fenceline emission could not be apportioned back to each
affected facility).  As previously explained, amendments to EPA Method
201A were proposed on March 26, 2009 (74 FR 12970). The amendments add a
particle-sizing device to allow for sampling of PM2.5, PM10, or both
PM10 and PM2.5.  Until such time that Method 201A amendments are
finalized and sufficient test data using that method can be collected
for coal thermal dryers, determinations of the need to add separate
PM2.5 and/or PM10 emission limits to Subpart Y, the BDT for PM2.5 and/or
PM10 emissions, and the appropriate emission limits applicable to coal
thermal dryers cannot be made.

<IP_ADDRESS>	Condensible PM Emission Limits

Comment:  Two commenters (028 and 035) agree that condensible emissions
are negligible for coal handling equipment because the ambient operating
temperatures are inadequate to volatilize trace elements, and the
process conditions will not form trace sulfur, nitrogen, or other
species with vapor pressures to enable condensation as PM.  For these
reasons, the commenter agrees with EPA’s decision not to propose a
separate NSPS for CPM.

Response:  Depending on the composition of an exhaust gas stream from a
process, the PM emitted can consist of both a FPM fraction and a CPM
fraction.  The CPM fraction remains in a gaseous form in the exhaust
stream until it is released into the atmosphere where it condenses to a
solid form.  Current test methods do not reliably measure the CPM
fraction from a source.  As previously explained, amendments to EPA
Method 202 were proposed on March 26, 2009 (74 FR 12970).  The
amendments to Method 202 revise the sample collection and recovery
procedures of the method to provide for more accurate and precise
measurement of CPM.  Until such time that Method 202 amendments are
finalized and sufficient test data using the revised method can be
collected for coal thermal dryers, a determination of the need to add a
separate PM emissions limit for CPM emissions from coal thermal dryers
cannot be made.

<IP_ADDRESS>	  Selection of Proposed PM Emission Limit Level

Comment:  Many commenters (021, 027, 028, 035, 039, 040, and 044)
disagreed with the selection of the 0.005 gr/dscf PM emission limit
level proposed for coal handling equipment using fabric filters for
several reasons.  Commenters stated that EPA failed to meet its
obligations under the CAA by using emissions data collected for another
industry group (nonmetallic mineral processing plants regulated under 40
CFR part 60, subpart OOO) to select the PM emission limit level for coal
preparation plants.  CAA section 111 obligates EPA to make its
determinations based on sound information that is directly relevant to
the industry being affected. EPA has not demonstrated that emissions
test data from Subpart OOO facilities are “representative” of
“achievable” emission levels for Subpart Y facilities.  Furthermore,
EPA’s use of the Subpart OOO test data to justify PM emission limits
for Subpart Y facilities that are lower than the corresponding PM
emission limits for Subpart OOO facilities is not justifiable.  EPA’s
own analysis of the data for Subpart OOO leads to a conclusion that
0.010 gr/dscf is an achievable NSPS.  The proposed PM emission limit
level of 0.0050 gr/dscf for Subpart Y does not reflect BDT.  Commenter
021 stated that 0.005 gr/dscf is well below BACT limits currently
applied to coal handling processes. No rationale was presented in the
proposal justifying an emission limit of 0.005 gr/dscf for point sources
of this size.  These point sources do not represent a significant
contribution to the NAAQS or Class II Prevention of Significant
Deterioration (PSD) PM increment and rarely have any modeled impact
outside the property boundary of the affected facility.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice are based on data from coal
preparation and processing plants (see 74 FR 25313 and Section 3 of this
document).

2.4.7	Opacity Limits

<IP_ADDRESS>	Method 9 Accuracy and Limitations

Comment:  Several commenters (028, 034, and 035) stated concerns about
use of Method 9 to measure opacity at any level below 10 percent.
Commenter 034 stated that because the accuracy of a certified visible
emissions observer can be as much as +7.5 percent, the lowest compliance
level set should be 10 percent opacity.  An action level of 5 percent
could be set for taking correction action.  Commenters 028 and 035
stated concerns about the use of Method 9 to measure opacity at any
level below 10 percent, given Method 9’s known measurement bias, and
the fact that any visible emissions observed during a Method 9 test must
be recorded as 5 percent.

Response:  The commenters have misrepresented the discussion in Method 9
about potential for positive bias when applying the method.  First, the
method states that under the highest contrast conditions when the
greatest potential for a positive bias exists, the study showed that
100 percent of the measurements of black smoke were read with a
positive error of less than 7.5 percent.  Further, the method states
that the study showed that 99 percent of the measurements were read with
a positive error of less than 5 percent.  The statistical results for
white smoke measurements are a little different but similar.  This means
that fewer than 5 out of 100 observers ever showed a positive bias of
more than 5 percent, and fewer than 1 in 100 showed more than
7.5 percent positive bias.  Under less than high contrast conditions,
which are conditions more normally encountered, the potential for
positive bias is even less.  The study shows that a 95 percent upper
confidence interval for the composite data ranges from about +5.4
percent opacity at the 5 percent opacity level to about +1 percent at
the 20 percent opacity level.  The composite data show a 95 percent
confidence range that is negative for opacity greater than 25 percent
(i.e., the method under-predicts actual opacity).  The study does not
support a conclusion that there is a known positive measurement bias
when using Method 9.  Further, there is no technical reason not to apply
Method 9 for measuring visible emissions less than 5 percent opacity.
The opacity standards proposed for Subpart Y are based on 6-minute
averages which are made up of a series of individual opacity readings,
each in 5 percent increments.  However, the resulting averages can be
less than 5 percent and even less than a whole number.

<IP_ADDRESS>	Selection of Proposed Opacity Limit Level

Comment:  Two commenters (028 and 035) stated that the units that EPA
has selected as the basis for the proposed opacity limit are not broadly
representative of new coal-handling facilities at power plants.  The
commenters do not believe EPA has sufficiently explained its decision to
use a smaller dataset in its Subpart Y proposal than in the Nonmetallic
Mineral Processing Plants NSPS (40 CFR 60 subpart OOO) rulemaking, or
why EPA chose to ignore the higher opacity levels observed at crushers.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice included a revised opacity limit for
coal-handing equipment constructed, reconstructed, or modified after
April 28, 2008, based on both performance test data and air permit
limits specific to existing coal handling equipment (see 74 FR 25314 and
Section 3 of this document).

<IP_ADDRESS>	Fabric Filters

Comment:  One commenter (036) expressed concern that fabric filters
cannot achieve the proposed 5 percent opacity limit.  The dust control
effectiveness of fabric filters is only determined by looking at opacity
coming out of the stack, and by stack testing.  If the entire fabric
filter and its pickup ductwork, the source, as well as the fabric filter
purge system, were read by Method 9, (instead of just the fabric filter
stack), most fabric filters would not be able to meet the proposed 5
percent opacity.  If fabric filters were read while bags are being
changed, and while bins are being manually emptied, they wouldn’t even
meet a 20 percent opacity limit.  Also, with fabric filters, plant
personnel have to frequently bang on the ductwork to make the dust move,
so that it doesn’t accumulate and eventually spontaneously combust.
If fabric filter stacks were read while the ductwork was being cleaned,
the fabric filter would not meet the opacity standard.  Fabric filters
are difficult to operate in a steady condition due to constantly
changing weather conditions, and feedstock conditions.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice included a revised opacity limit for
coa- handing equipment constructed, reconstructed, or modified after
April 28, 2008, based on both performance test data and air permit
limits specific to existing coal-handling equipment (see 74 FR 25314 and
Section 3 of this document).  Opacity data for coal-handing equipment at
coal preparation and processing plants indicate that fabric filters can
meet the revised limit.

<IP_ADDRESS>	Fugitive Emissions Sources

Comment:  One commenter (029) stated that EPA should establish a
different opacity limit for non-stack fugitive releases.  The proposed
opacity limit for all affected facilities not installing PM CEMS is 5
percent.  This is applicable to both non-stack releases and stack
releases.  The commenter notes that 5 percent is exceeding this limit.
Visible emissions at a 5 percent limit may be practical for stack
releases connected to a bag filter.  This may not be practical for
non-stack fugitive releases.  Also, the commenter stated that 5 percent
opacity for fugitive releases in most cases constitutes lower PM mass
emissions than a 5 percent opacity for stack releases.  This is due to
the fact that a much lower flow rate of exhaust air is involved with
non-stack fugitive releases.  If both types of releases are compared
with the same limit, it may be overly restrictive for non-stack fugitive
releases.  The commenter requests that EPA reconsider the 5 percent
opacity limit for fugitive non-stack releases and suggests keeping the
existing NSPS limit of 20 percent.

Response:  Revised amendments to Subpart Y published in the May 27,
2009, supplemental proposal notice included a revised opacity limit for
coal-handling equipment constructed, reconstructed, or modified after
April 28, 2008, based on both performance test data and air permit
limits specific to existing coal-handling equipment (see 74 FR 25314 and
Section 3 of this document).  The final rule includes additional
revisions based on comments and information submitted regarding the
supplemental proposal.  Opacity data for coal-handling equipment
fugitive non-stack releases at coal preparation and processing plants
indicate the revised limit can be met.

<IP_ADDRESS>	Coal Storage Silos

Comment:  One commenter (036) stated that coal storage silos should be
exempt from any opacity standard less than 20 percent.  Because silos
are an improvement over open stockpile dumping, they should not be
overly restricted for opacity.  Most of the time the commenter’s silos
can meet 7 percent opacity when coupled with fogging systems.  However,
the silos occasionally barely complied with the 20 percent opacity limit
when the commenter had utilized fabric filters for dust control.

Response:  Coal storage silos continue to be subject to the same opacity
standards as all affected coal processing, conveying, storage, and
transfer systems.  There has been no change with respect to the
applicability of Subpart Y to coal storage silos.  Revised amendments to
Subpart Y published in the May 27, 2009, supplemental proposal notice
included a revised opacity limit for coal-handing equipment constructed,
reconstructed, or modified after April 28, 2008, based on both
performance test data and air permit limits specific to existing coal
handling equipment (see 74 FR 25314 and Section 3 of this document).
The final rule includes additional revisions based on comments and
information submitted regarding the supplemental proposal.  Opacity data
for coal-handing equipment, including coal storage silos, at coal
preparation and processing plants indicate the revised limit can be met.

2.4.8	Work Practice Standards

<IP_ADDRESS>	Alternative to Opacity Standards

Comment:  A number of commenters (028, 029, 030, 035, and 038) stated
that EPA should adopt work practice standards as an alternative to the
opacity limit.  Effective work practice standards could include