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State of Montana 

y Montana Department of Department of Environmental Quality 

:EwiROffllEITAL QUALITY Permitting and Compliance Division 



January 2003 



Roundup Power Project 
Final Environmental Impact Statement 






Montana Department of 

Environmental €m jjuty 



Judy Martz, Governor 



P.O. Box 200901 • Helena, MT 59620-0901 • (406) 444-2544 • Website: www.deq.state.mt.us 



January 2003 



Dear Reader: 



Enclosed is the Final Environmental Impact Statement (EIS) for the proposed Roundup 
Power Project. The Final EIS adopts the Draft EIS as a part of the final, responds to public 
comments, and provides substantive changes, which amend the Draft EIS in response to public 
comments. 



About 100 copies of the Draft EIS were distributed in November 2002 for a 30-day 
comment period. During the comment period, the Department of Environmental Quality (DEQ) 
held a public hearing in Roundup to receive oral and written comments on the Draft EIS. In 
addition to oral testimony, DEQ received 80 letters, about 500 post cards, and more than 1200 e- 
mails commenting on the Draft EIS. All comments were reviewed and considered in preparing 
the Final EIS. Comments that provided new data, questioned facts or analysis, or raised 
questions or issues bearing directly on the alternatives or environmental analysis have been given 
responses in this Final EIS. Comments expressing personal opinions were considered but have 
received no direct response. 

DEQ has selected the Proposed Action as modified by the Landfill Alternative as the 
preferred alternative. The final decision will be made in the Record of Decision that will be 
released no sooner than 1 5 days from the issuance of this Final EIS. 

DEQ appreciates the public's involvement in preparing this Final EIS. Additional copies 
are available upon request while the supply lasts. The Draft and Final EISs are also posted on 
DEQ's web site at www.deq.state.mt.us . A copy of the Record of Decision will be sent to 
everyone who receives the Final EIS. 

Sincerely, 




Jan P. Sensibaugh 
Director 



Roundup Power Project Final Environmental Impact Statement 



Table of Contents 

Chapter 1 Introduction 1-1 

1.1 Public Participation 1-1 

Chapter 2 Summary 2-1 

2.1 The MEPA Process for the Roundup Power Project 2-1 

2.2 Proposed Action 2-2 

2.3 Issues of Concern 2-2 

2.4 Alternatives Considered and Eliminated 2-3 

2.5 Alternatives Analyzed in Detail in the DEIS 2-4 

2.6 Expected Impacts From the Alternatives 2-5 

2.7 Agency -Preferred Alternative 2-8 

Chapter 3 Sources of DEIS Comments 3-1 

Chapter 4 Comments and Responses on the DEIS 4-1 

Chapter 5 Modifications and Corrections to the DEIS 5-1 

Appendix A Letters from Local, State and Federal Agencies and Tribes A-l 

Tables 

Table 2-1 Summary of Alternatives Considered but Eliminated 2-17 

Table 2-2 Alternatives Comparison Summary 2-19 

Table 3-1 Comments from Local, State and Federal Agencies and Tribes 3-1 

Table 3-2 Comments from Private Citizens and Organizations 3-2 

Table 3-3 Comments from Project Proponent 3-6 

Table 3-4 Comments from Roundup Power Project Public Hearing 3-7 

Table 3-5 Comments from Draft Permit Comment Period 3-7 

Table 3-6 Comments from Private Citizens via Email 3-8 

Table 4-1 Local Electrical Generation Facility Impact Fee for Local Governmental Units 
and School Districts 4-30 

Table B-6 Visibility Impacts from the FLM 1990 Modeling Analysis 5-4 

Table B-6.1 Visibility Impacts from the FLM 1992 Modeling Analysis 5-4 

Table B-l 1 Comparison of Modeling Results from the Proponent and NPS for Class I Area 
Visibility Impacts 5-6 



Montana DEQ i Table of Contents 



Final Environmental Impact Statement Roundup Power Project 



Table B-12 Modeled and Measured Yellowstone Visibility Data (Days with Predicted 

Impacts Greater than 5% Change in Light Extinction) 5-9 



Figures 

Figure 2-1 Vicinity Map 2-15 

Figure 3-7 Land Use 5-11 



Table of Contents ii Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



CHAPTER 1 
INTRODUCTION 

This Final Environmental Impact Statement (FEIS), prepared by the Montana Department of 
Environmental Quality (DEQ), adopts the Roundup Power Project Draft EIS (DEIS), 
November 18, 2002, as the FEIS with modifications contained in this document. 

The FEIS contains a summary of major conclusions and supporting information from the 
DEIS including the agency's recommendation (Section 2.0), a list of all sources of written 
and oral comments received during the public comment period on the DEIS (Section 3.0), the 
agency's responses to substantive comments which includes a summary of the comments 
received and disposition of the issues involved (Section 4.0), and a description of 
modifications and corrected errors to the DEIS (Section 5.0). The decision to issue or deny 
an Air Quality permit for the Roundup Power Project (Project) and rationale for this decision 
will be included in the Record of Decision (ROD) to be made public no sooner than 15 days 
after the FEIS release to the public. 



1.1 Public Participation 



One of the prime objectives under Montana Environmental Policy Act (MEPA) is to involve 
the public through each step of the decision-making process. This is accomplished by (1) 
seeking preliminary comments on the purpose and benefits for the pending action and 
potential issues of concern, (2) requesting and evaluating public comments about the 
environmental review, and (3) informing the public of the final decision and the justification 
for that decision in the form of a Record of Decision after review of the FEIS. 

The DEIS was issued for public comment November 18, 2002. To seek comments from the 
public on the DEIS, the DEQ conducted a public hearing on Thursday, December 5, 2002 in 
Roundup, Montana. 

The location for the meeting was selected based on the area likely to experience the greatest 
impacts from the Project. 

During the 30-day public comment period for the DEIS, comments were also submitted to 
the DEQ in writing. All substantive comments received during the public comment period 
have been reproduced with DEQ responses in Section 4.0 of this FEIS. Sources of public 
comments are listed in Section 3.0 with associated comment identification numbers. 



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Roundup Power Project Final Environmental Impact Statement 



CHAPTER 2 
SUMMARY 

This summary presents a condensed version of information contained in the DEIS for the 
Project with modifications subsequent to the public comment period. Two alternatives to 
components of the Proposed Action, in addition to a No- Action Alternative were analyzed in 
the DEIS. If interested in more detailed information, please refer to the DEIS. The FEIS and 
the DEIS can be obtained from the DEQ web site at http://www.deq.state.mt.us or, while 
supplies last, by contacting: 

Mr. Greg Hallsten 

Montana Department of Environmental Quality 

1520 East 6 th Avenue 

P.O. Box 200901 

Helena, MT 59620 

(406) 444-3276 

2.1 The MEPA Process for the Roundup Power 
Project 

The Project is a proposed coal -fired electric generation plant located on private property 
about 35 miles north of Billings and 13 miles south-southeast of Roundup, Montana. A map 
of the Project Area is shown in Figure 2-1. The Bull Mountain Development Company 
(Proponent) submitted an application for an air quality permit to the DEQ on January 14, 
2002. The application, which had to meet the requirements of the Clean Air Act of Montana 
(75-2-101 et seq., MCA and ARM 17.8.701 et seq.), was found to be adequate on July 22, 
2002. This started a mandatory 180-day time frame for the environmental review under the 
MEPA. The purpose of the Proposed Action is to permit activities that provide additional 
electricity to meet increasing demand for power within the western United States. 

Procedures governing the EIS analysis process in Montana are defined in administrative rules 
implementing the MEPA. This law requires an EIS to be prepared if any action taken by the 
State of Montana may significantly affect the quality of the human environment (as defined 
in MEPA). The EIS was written to meet the requirements of MEPA and the administrative 
rules implementing MEPA. 

The Montana DEQ is the lead agency and is responsible for completing an EIS before issuing 
the Final Air Quality Permit (75-1-201, MCA). 

The scope of the EIS includes actions, alternatives, and analyses necessary for the DEQ to 
make decisions regarding permits or approvals for the Proponent to construct and operate the 
Project. Permitting decisions will be based on the environmental effects and consequences 
relative to legal standards as documented in the EIS, along with other information presented 
during agency decision-making processes. 



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Final Environmental Impact Statement Roundup Power Project 



2.2 Proposed Action 



The Proponent has submitted an application to the DEQ for an air quality permit. The Project 
is designed to be a mine-mouth generating facility using coal from the existing Bull 
Mountains Mine (Mine) adjacent to the Project. To meet its coal supply needs, the Project 
Proponent has entered into contractual agreements with the Mine to purchase approximately 
2.7 million tons of coal per year. Coal would be delivered from the Mine to the Generation 
Plant by a 4,000-foot-conveyor system. 

The Project would be built specifically to burn coal. The mine-mouth fuel source of the 
Project is intended to provide stable pricing and reliability for base load power assisting 
utilities in more reliably serving industrial, commercial, and residential customers. 

Two electric generating units, each with a pulverized coal-fired boiler and a steam turbine 
generator, are proposed. Each unit would be designed to generate a nominal 390 megawatts 
(MW) gross (350MW net) electrical capacity year-round on a 24-hour-per-day basis, except 
during planned maintenance periods and occasional repair outages when one unit would 
normally remain operating. Four to six groundwater wells, approximately 8,500 feet deep, 
are proposed as the Project's water supply. 

A new 161 kilovolt (kV) transmission system (i.e., three circuits), approximately 28.2 miles 
long, would be built from the Generation Plant to Northwestern Energy's Broadview 
Substation, interconnecting with the northwest transmission network. Power generated by 
this facility would be sold to all classes of electricity consumers (residential, municipal, 
cooperative, commercial, and industrial customers). The route for the transmission lines 
would be within or immediately adjacent to the Mine's rail corridor. 

Air pollution emissions, wastewater discharges, solid waste disposal, and other significant 
aspects of the Project would comply with applicable permits and environmental 
requirements. 

2.3 Issues of Concern 

Before preparation of the DEIS, DEQ invited the participation of affected federal, state, and 
local government agencies, Indian tribes, the Project sponsors, and interested persons and 
groups to discuss issues, concerns, and opportunities, and to help identify the scope of the 
DEIS. During this scoping process DEQ also identified possible alternatives to the Project. 

On April 4, 2002, a public scoping meeting was held by the DEQ in the City of Roundup to 
identify issues and concerns. Comments were also accepted by mail. In addition, the Project 
Proponent has sought public participation by making three presentations to the Legislature's 
Transition Advisory Committee, by participating in the Governor's Conference on Economic 
Development on March 7, 2002, in Billings, and by making a presentation to the executive 
board of the Big Sky Economic Development Authority in Billings. 

The issues of concern raised during the public and agency scoping process include: 



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Roundup Power Project Final Environmental Impact Statement 

Socioeconomic Effects 

• Impacts on schools, law enforcement, and other public services due to in-migration 
of Generation Plant workers. 

• Changes in social setting and attitudes due to in-migration of Generation Plant 
workers, impacts associated with increased traffic, and infrastructure impacts. 

Air Quality 

• Impacts due to pollution emissions during Generation Plant operation. 

• Global climate impacts due to greenhouse gas emissions during Generation Plant 
operation. 

• Cumulative visibility impacts. 

Water Resources 

• Impacts on surface water or groundwater quality due to solid waste disposal and 
other Generation Plant activities. 

• Impacts on groundwater levels and supplies due to withdrawals during Generation 
Plant operation. 

Noise 

• Disturbance of nearby residents by noise from Generation Plant construction and 
operation. 

Infrastructure 

• Adequacy of existing transmission system to carry the Generation Plant output. 

DEQ Regulatory Actions and Response 

• Evaluation/regulation for combined impacts of the Generation Plant and other 
industrial developments in the region 

• Monitoring of the Generation Plant construction process, including depth of 
groundwater wells, and response to Generation Plant emissions exceedances of 
permitted levels 

• Accidents during Generation Plant operations and issues involving the proposed 
landfill 

2.4 Alternatives Considered and Eliminated 

The Project Proponent identified numerous alternatives to the Project, including: 

• Fuel Sources 

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Final Environmental Impact Statement Roundup Power Project 

• Water Supplies 

• Cooling Systems 

• Combustion Systems 

• Solid Waste Systems 

• Wastewater Discharge Systems 

• Emission Control Systems 

• Generation Sites 

The alternatives described in this section were eliminated from further consideration because 
they did not meet the stated purpose for the Project or were found to be economically 
unreasonable. A summary comparison of the alternatives considered and eliminated is 
provided in Table 2-1. 

2.5 Alternatives Analyzed in Detail in the DEIS 

There are two alternatives to components of the Project: 

• Landfill Alternative - Alternative to in-mine waste disposal from the Generation 
Plant. 

• 230kV Transmission System - Alternative transmission voltage for interconnection 
into the transmission grid of the western United States at Broadview Substation. 

In addition, a No- Action Alternative was analyzed in detail. 

Landfill Alternative 

Over the life of the Project, construction and operation of additional landfill cells on the 
Generation Plant site is proposed as an alternative to moving most of the solid waste to the 
Mine for disposal. The landfill would be a state-of-the-art facility designed with two cells, 
providing 60 acres for solid waste storage. The disposal area would be lined for the 
protection of groundwater and provided with a leachate collection system not to exceed 10 
acres to remove leachate and storm water that collects on top of the lining. 

230kV Transmission System Alternative 

Each generating unit would be designed to generate nominally 390MW gross (350MW net) 
electrical capacity year round on a 24-hour per day basis. As an alternative to the three 
circuits of 161kV transmission lines from the Generation Plant to the Broadview Substation, 
two single-circuit 230kV lines on wood pole H-frame structures in the same corridor as the 
Project would be constructed. This would require a different transformer and associated 
equipment to support connection to a higher voltage transmission line. Equipment and 
construction would be similar to the 161kV Transmission System. Constructing the 230kV 
Transmission System Alternative would need a certificate under the Montana Major Facility 
Siting Act. 



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Roundup Power Project Final Environmental Impact Statement 



Northwestern Energy's Broadview Substation is connected to the transmission grid in the 
northwest and coordinated by the Western Electricity Coordinating Council (WECC). 
Improvements are planned for the system to allow approximately 500MW to flow west 
towards Bonneville Power Administration's (BPA) Garrison Substation and approximately 
200MW to flow south to PacifiCorp's Yellowtail Substation. Both transmission providers 
will perform studies to identify necessary upgrades to support this flow. 

No-Action Alternative 

Under the No-Action alternative, the Generation Plant and the 161kV Transmission System 
to the Broadview Substation would not be constructed. The State of Montana would not issue 
the Final Air Permit for the Project. The purpose and need for the Project would not be met 
under the No- Action Alternative. 

2.6 Expected Impacts From the Alternatives 
Affected Environment 

The Project would be located approximately 35 miles north of Billings and 13 miles south- 
southeast of the City of Roundup. The affected environment considered for the Generation 
Plant Study Area encompassed all of the land in Section 15, Township 6 North, Range 26 
East in Musselshell County, Montana. Approximately 208 acres would be devoted to the 
Generation Plant. The Landfill Alternative would occupy an additional 70 acres of land 
adjacent to the Generation Plant. The proposed Transmission System and 230kV Alternative 
would be approximately 28 miles in length, crossing Musselshell and Yellowstone Counties 
from the Generation Plant to Broadview Substation to the west. 

The air quality in the Project Study Area (Generation Plant and Transmission System) is well 
within the applicable ambient air quality standards for all criteria pollutants. The Generation 
Plant would be located along the crest of the drainage divide between the Musselshell and 
Yellowstone rivers. There are no surface water bodies within the Generation Plant Study 
Area. There are two main aquifers: the shallow sandstone aquifers and the Madison aquifer, 
which is the proposed water source for the Project. 

From on-site soils and vegetation surveys, it has been determined that there are no identified 
wetland resources within the Generation Plant Study Area. No federal or state-listed plant or 
wildlife species of concern are known to occur within the vicinity of the Project. The Bull 
Mountains surrounding the Project support a good diversity of wildlife. Many of these 
species, particularly non-game species, could occur at least seasonally on or adjacent to the 
Project site. 

A total of 65 cultural resources have been identified within the area of potential effect for the 
Project. Overall, the Project site contains visual resources such as Signal Mountain and the 
Bull Mountains. Foothills, ephemeral drainages, riparian vegetation, annual grasslands, and 
large expanses of ponderosa pine influence the natural visual setting. Human built features 
include: U.S. Highway 87, dispersed rural residential housing and agricultural fields along 
with grazing areas. No BLM or U.S. Forest Service (FS) lands occur within or near the 
Project site. 

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Final Environmental Impact Statement Roundup Power Project 



Environmental Consequences 

Where potential impacts to a resource were identified, an evaluation was conducted to 
determine if one or more actions would be effective in avoiding or reducing (e.g. intensity 
and/or duration) the potential impact. 

Proposed Action 

The Project was assessed for compliance with Montana Ambient Air Quality Standards 
(MAAQS) and the National Ambient Air Quality Standards (NAAQS), and Prevention of 
Significant Deterioration (PSD) increment levels as part of the air resources analysis. The 
area of impact included surrounding Class I areas (Yellowstone National Park, UL Bend 
Wilderness Area, North Absaroka Wilderness Area, and Northern Cheyenne Indian 
Reservation). The Project, by itself, was above the PSD modeling significance levels. 

The Generation Plant would directly impact approximately 208 acres of mostly 
grass/shrubland habitat with some ponderosa pine. Due to the widespread, common nature of 
this habitat, and because no federally-listed threatened and endangered species are known to 
occur in these areas, the loss to wildlife habitat, cattle grazing and agricultural practices 
would result in a low impact to these resources. 

Impacts to groundwater from in-mine storage of waste is unknown. More studies would be 
required to assess impacts. Zero discharge would cause low impacts on groundwater 
resources from wastewater ponds and a solid waste landfill. 

Soil erosion impacts would be low due to control of runoff from the Generation Plant. 

Archaeological sites within three miles of the Generation Plant site would be impacted, of 
which eight are considered visually sensitive. The Generation Plant chimneys would visually 
impact residents and travelers. 

Full economic benefits realized from implementation of the Project may include tax benefits 
to Musselshell County and the State of Montana. Jobs would also be a benefit during 
construction and during the life of the Project. 

Portions of a 28.2-mile long and 300-foot wide right-of-way would result in ground 
disturbance caused by transmission structures and access roads associated with the Project. 
The transmission right-of-way would remain available for wildlife habitat, cattle grazing and 
agricultural practices. Due to the widespread, common nature of this habitat, and because no 
federally-listed threatened and endangered species are known to occur in these areas, the loss 
to wildlife habitat, cattle grazing and agricultural practices would result in a low impact to 
these resources. 

If cultural or paleontological resources are discovered during Project construction and cannot 
be avoided, recovery of these resources would ensure no irreversible and irretrievable loss to 
cultural resources. Visual impacts would occur at road crossings and from scattered 
residences along the transmission line corridor. 

The Project operations would result in the consumption of approximately 8,000 tons of coal 
per day from the adjacent Mine, which would be irreversibly replaced by the generation of 
electricity. The loss of these coal reserves would be offset by the benefit of electricity 
generation by the Project. 

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Roundup Power Project Final Environmental Impact Statement 



Landfill Alternative 

Approximately 70 additional acres would be disturbed to develop the waste disposal landfill 
and associated ditches and access road. Impacts would be similar to Proposed Action with 
minor soil erosion caused by the transport of waste from the Generation Plant to the 
expanded landfill site. 

The Landfill Alternative would have no impacts on threatened and endangered species. The 
expansion of the landfill would be more noticeable than the Proposed Action, but would 
result in only low visual resource impacts. As with the Proposed Action, socioeconomic 
benefits would result from construction jobs, taxes for government agencies and social 
services, and long-term jobs from operation and maintenance of the facility. 

230kV Transmission System Alternative 

The 230kV alternative would require fewer circuits and larger conductors, taller poles but 
wider spans between poles, and different hardware than a lower voltage system to transport 
the Project's 750MW. During construction, existing roads would be used where feasible but 
some new roads and upgrades to existing roads would likely be needed. Ground disturbance 
on the right-of-way would result in permanent loss of acreage for the pole footings and any 
new access roads. Temporary disturbance at work areas could be returned to pre-project use 
following construction. No impacts would result to threatened and endangered species. 

As with the Proposed Action, socioeconomic benefits would result from construction jobs, 
taxes for government agencies and social services, and improved transmission infrastructure. 

Visual impacts would occur at road crossings and from scattered residences along the 
transmission line corridor. 

Cumulative Impacts 

Cumulative impacts result from the incremental impact of the Project when added to other 
past and present actions and future actions under state review. 

Residential and Commercial Development 

Currently residential and commercial developments are few in the Generation Plant and 
Transmission System study areas and surrounding Musselshell and Yellowstone counties. 
Eight rural residences are located within a mile of the Generation Plant. The City of 
Roundup, located approximately 13 miles to the north of the Generation Plant, is the closest 
urban development. 

According to county records, no new residential developments are currently planned for 
these study areas. However, given the amount of recent residential development, and the 
amount of land in these study areas that is subdivided, it is reasonable to assume that a small 
level of development would occur in the future. 

The nearest commercial establishment is the Brandin' Iron Saloon, which is located along 
U.S. Route 87, approximately two miles north-northwest of the Project study area. A 
convenience store and a log furniture store are proposed along U.S Route 87, approximately 



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Final Environmental Impact Statement Roundup Power Project 



two miles northwest of the Project study area. Other plans for the area include a recreational 
vehicle park and golf course. 

Industrial Development 

The PM Mine, an underground coal mining operation, was located partially in Section 14, 
east of the Project study area. The PM Mine ceased operation in the 1990s, but the Bull 
Mountains Mine No. 1 plans to resume mining of the same area. No new coal mines or other 
industrial developments are known to be proposed for the Generation Plant or Transmission 
System study areas. 

Infrastructure Development 

Roads 

Portions of U.S. Route 87 between Roundup and Billings were upgraded during the 1990s. 
The only known proposed future upgrades are the construction of acceleration-deceleration 
lanes where Old Divide Road (the proposed access road to the Generation Plant and 
associated facilities) intersects Route 87. 

Transmission 

The major backbone of the Montana transmission system is the two 500kV lines that run east 
to west across the state and through the Broadview Substation (the Project connection point). 
The 500kV lines connect to the BPA system at Garrison Substation, west of Broadview 
Substation. Additionally, 230kV transmission connects Broadview Substation to the 
PacifiCorp system at Yellowtail Substation southwest of the Transmission System Study 
Area. 

According to BPA, major transmission improvements to the BPA system are planned. These 
improvements would include substation upgrades and transmission line additions between 
Montana and the Pacific Northwest. 

The transmission lines from the Project would be inside or immediately adjacent to the 
existing railroad right-of-way for the Mine railroad to Broadview Substation, where the lines 
would connect to the Northwestern Energy system. No additional land would be disturbed. 

2.7 Agency-Preferred Alternative 

The DEQ Preferred Alternative is the Proposed Action, with the addition of the Landfill 
Alternative for long-term solid waste disposal instead of long-term disposal in the Mine. In 
this alternative, solid waste would be stored in landfill cells adjacent to the Generation Plant 
site for the life of the Project. 

The alternative of disposing waste in the off-site landfill is preferred over the Proposed 
Action of long-term disposal of waste in the adjacent Mine, because it would result in the 
least impacts to environmental resources. The uncertainties associated with in-mine storage 
of waste make the Proposed Action a higher risk for causing impacts and possible 
contamination to soils, water bearing geological zones, and groundwater resources. In 
comparison, the use of lined and monitored landfill cells would minimize the risk of these 



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Roundup Power Project Final Environmental Impact Statement 



impacts in the future. More information is needed to fully understand impacts from in-mine 
storage. Therefore, the Landfill Alternative is preferred. 

With the construction and operation of the Proposed Action or the two alternatives (i.e., 
Landfill and 230kV Transmission), all resource areas, with the exception of fisheries, would 
experience some adverse environmental impacts (refer to Table 2-2). Impacts that would 
result to vegetation and wildlife would include the loss of approximately 208 acres of 
grass/shrubland habitat for the Proposed Action or the action alternatives. However, this 
habitat is common and widespread in this portion of Montana, so impacts would be low. No 
federally-listed or state sensitive species are known to exist in the Project study areas. 

Air quality impacts were not a factor in selecting the Preferred Alternative, as impacts would 
not be measurably different under the Proposed Action or with selection of either of the 
action alternatives. Air resources were identified as having the highest Project-related 
impacts with most impacts ranging from low to moderate. A high impact to three Class 1 
Areas (i.e., Yellowstone National Park, North Absaroka Wilderness Area, and Northern 
Cheyenne Reservation) was identified from Project operations impairing visibility in these 
areas during specific periods of time each year. 

Finally, the socioeconomic benefits of preferring the Proposed Action and the Landfill 
Alternative (i.e., the Preferred Alternative), as well as the benefits of adding the base load 
generation at this location and using the proposed fuel source, would outweigh the potential 
environmental consequences of constructing and operating the Project as the Preferred 
Alternative. 

DEQ's preference for this alternative could change in response to public comments on the 
DEIS, new information, or analysis completed as part of this FEIS. 

Recommended Mitigation 

Mitigation measures cannot be required by DEQ without a request from the Project 
Proponent that they be placed in a permit (75-l-201(5)(a) and (5)(b), MCA). The Project 
Proponent may request that any or all of the mitigation measures that pertain to expected 
impacts from their proposed activities be placed in the permits. In those instances when the 
Proponent chooses not to include a mitigation measure in a state permit, the Project 
Proponent may decide to perform the proposed mitigation voluntarily. 

Construction and Maintenance Access 

CM-l All construction vehicle movement outside the 300 foot- wide easement would 
normally be restricted to predesignated access as negotiated with the landowner, 
contractor-acquired access, or public roads. Construction activities for the 
transmission lines would be restricted to and confined within the predefined limits. 

CM-2 Roads would be built at right angles to the streams and drainages to the extent 
practicable. 

CM-3 Culverts or rock crossings would be installed where needed. 

CM-4 Existing roads would be utilized for construction where feasible. 



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CM-5 No paint or permanent discoloring agents would be applied to rocks or vegetation to 
indicate limits of survey or construction activity. 

CM-6 Prior to construction, all supervisory construction personnel would be instructed on 
the protection of important cultural, paleontological, and ecological resources. 

Air Quality 

AQ-l Suggested design and operation mitigation measures include 

• Coal cleaning and/or coal preparation 

• NOx control 

• Carbon sequestration, such as planting trees 

Earth Resources 

ER-l A Landfill Management Plan would be developed to address potential 
environmental impacts from proposed waste disposal. 

Water Resources 

WTR-l Alternate water supplies may be necessary for a small number of wells that are 
proven to be directly influenced by reduction of recharge due to the plant 
construction. 

WTR-2 Installation of groundwater monitoring wells in the vicinity of the landfill area 

would serve to identify groundwater impacts from leachate releases. Groundwater 
monitoring wells should be installed prior to startup of landfill operation in order to 
establish baseline conditions. A minimum of three groundwater monitoring wells 
would be required to characterize groundwater quality and flow direction beneath 
the landfill area. 

Waste and Cleanup 

WC-l No equipment would be refueled or greased within 100 feet of a wetland or 

perennial stream. In addition, fuels, oils, lubricants, herbicides, or other potentially 
hazardous materials would not be stored within 300 feet of a wetland or perennial 
stream. 

WC-2 A spill prevention plan would be developed that addresses containment and cleanup 
of spills affecting surface waters. 

Botanical Resources and Wetlands 

BW-l Existing vegetation would only be cleared from areas scheduled for immediate 

construction work and only for the width needed for active construction activities. 

BW-2 All reseeding mixtures used for reclamation would be certified weed-free. 



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Roundup Power Project Final Environmental Impact Statement 

BW-3 Effective soil erosion control and reseeding of disturbed areas not required for 
permanent access for the transmission line would be implemented to encourage 
revegetation. 

BW-4 Transmission line structures would be located to span streams and drainages. 

Wildlife Resources 

WR-l Harassment of wildlife would not be permitted at any time during Project 
construction activities. 

WR-2 Construction timing would be altered in specific identified areas where sharp-tailed 
and sage grouse leks are identified. 

WR-3 Install raptor diverters on transmission structures in specific identified locations to 
discourage raptor roosting and potential raptor predation on certain terrestrial 
species (e.g., sage grouse on strutting grounds). 

Cultural Resources 

CR-l Each cultural resource potentially affected by the proposed action should be more 
completely documented and evaluated so that a formal determination of National 
Register eligibility can be made by the State Historical Preservation Office (SHPO). 

CR-2 An assessment of effects should be performed if a cultural resource is determined 
eligible to the National Register. 

CR-3 Adverse effects should be avoided by Project redesign, if feasible, if a considerable 
cultural resource would be affected by ground disturbance. 

CR-4 Appropriate mitigations measures, including data recovery, should be implemented 
following consultation with the Montana SHPO, Native American tribes, and other 
interested parties if a National Register-eligible resource cannot be avoided through 
Project redesign. 

Visual Resources 

VR-l No paint or permanent discoloring agents would be applied to rocks or vegetation to 
indicate limits of survey or construction activity. 

VR-2 Wood poles or dulled metal surfaces would be used for the transmission line to 
reduce visual contrast. 

VR-3 In construction areas where ground disturbance would be substantial or where 

recontouring would be required, surface restoration would occur as required by the 
landowner. The method of restoration could consist of loosening the soil surface, 
replacing rocks or plants removed during transmission line construction, reseeding, 
mulching, installing cross drains for erosion control, placing water bars in the road, 
and filling unnecessary ditches. 

VR-4 To minimize ground disturbance over the transmission line route and/or reduce 

scarring (visual contrast) of the landscape, the alignment of any new access roads or 



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cross-country route would follow the landform contours in designated areas where 
practicable. 

VR-5 Non-specular conductors would be used to reduce visual contrast. 

VR-6 Where possible the edges of clearings in forested lands or tree groves would be 
feathered to avoid abrupt, straight lines. 

VR-7 Baffled strobe lights would be installed on Project chimneys to direct light upward 
rather than outward if strobe lighting is determined to be required by the Federal 
Aviation Administration (FAA). 

Noise 

N-l Careful evaluation of specifications and design selection of typical low-noise design 

options, equipment specifications, building and wall designs, and enclosure 
constructions would be made during the design process to ensure that the 
Generation Plant noise is not excessive. 

N-2 The Proponent would implement noise control measures at the Generation Plant, 

such as silencers for decreasing noise generated during boiler steam blowout for 
plant start-up and maintenance. 

N-3 If measured noise levels exceed Ld n 55 dBA at the sensitive receptors, then 

additional noise control measures would be installed, as necessary, to avoid adverse 
impacts on the sensitive receptors. 

Land Use and Safety 

LS-l Existing improvements, such as fences and gates, would be repaired or replaced to 
their condition prior to disturbance or as agreed to with the landowner, if they are 
damaged or destroyed by transmission line construction activities. 

LS-2 Temporary gates would be installed only with the permission of the landowner and 
would be restored to original condition prior to disturbance following transmission 
line construction. 

LS-3 All existing roads would be left in a condition equal to or better than their condition 
prior to the construction of the transmission line. 

LS-4 All new access not required for operations and maintenance of the transmission line 
would be closed using the most effective and least environmentally damaging 
methods appropriate to that area with concurrence of the landowner. 

LS-5 The Project would comply with any FAA requirements regarding public safety. 

LS-6 Warning signs and flag-persons would be used at all roadway crossings during 
transmission line construction for all state, federal, county, and local roads and 
highways. 

LS-7 To prevent problems with livestock during the transmission line construction, all 
fences and gates would remain closed at all times throughout construction unless 
specified otherwise by the agency manager or landowner. 



Chapter 2 2-12 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



LS-8 The Proponent and the construction contractors would coordinate activities with 
property owners to ensure continued access across the transmission line right-of- 
way for the use of property by the property owner. 

LS-9 Harassment of livestock would not be permitted at any time during Project 
construction activities. 



Montana DEQ 2-13 Chapter 2 



State Location 




140 Miles 



County Location 



Jyle 
FERGUS COUNT> 



Yejbw 
miter 
Reservoir Fiatwiiiow 



Roundup Power Project Location (Enlargement) \ 



rOBcationi 




4,000 Feet 



Figure 2-1 



Vicinity Map 



Roundup Power Project FEIS 



Legend 



Preliminary Transfer Location 



• Towns 



O Cities 



•k State Capital 



Conveyor Location 
Proposed Transmission 
Interstate Highway 
U.S. Highway 
State Highway 
County Road 



H — ' — i Proposed Railroad 
County Line 



Lake / Stream 



V> Montana Department <>r 

lEiiviRo™vrAi. Quality 



H$« 



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W:\Env_Roundup\Apps\General_location.mxd 



13122502 GenLoc Rev2 010803 AAA 



Table 2-1 Summary of Alternatives Considered But Eliminated 



Screening 
Criteria 



Energy Sources & Conveyance 



Alternative Fuel Sources 



Power Plant Processes 



Alternative Water Sources 



Cooling 
Systems 



Alternative Combustion Systems 



Generation 
Sites 



Waste Stream Treatment & Disposal 

Alternative Solid Waste Disposal Methods 



Alternative Pollution Control and Solid 
Waste Treatment 



Lower Sulfur 
Coal 



Synthetic Fuels 
{e.g., shale oil, 
tar sands, etc.) 



Coal Bed 
Methane 



Yellowstone 
River 



Musselshell 
River 



Shallow 
Aquifers 



Wet Cooling 



Alternative 
Boiler Types 



Gas Turbines / 
Combined Cycle 



Ash & Wet FGD 



Separate 
Bottom Ash 
from Waste 



Waste Rock 
Landfill 



Off-Site Landfill 

for Life of 

Project 



On-Site Landfill 

for Life of 

Project 



Technically feasible, 

however coal-fired 

powerplants are 

designed to burn 

specific coal. 

Therefore, not 

technically feasible 

using the current 

design. 



Cost would be much 

higher to transport 

coal from other 

mines. 



Technically feasible, 
but would not be 
feasible under 
current design. It is 
doubtful that the 
source could not 
solely support 
proposed load 



There are no 

conveyances 

available for fuel 

supply. 



Technically feasible, 
but would not be 
feasible under 
current design. 
Source may not be 
available as fuel 
supply after 2008 



There are no 

conveyances 

available for fuel 

supply. 



Technically feasible, 
but not feasible 
under the current 
design. There are 
many gas facilities 
planned throughout 

the country 

competing for limited 

supplies of gas. 



There are no 

conveyances 

available for fuel 

supply. 



Techically feasible, 

however not feasible 

under current design 

and for this size 

facility. Design is 

totally different and 

tied to gas or 

hydrogen. 



There are no 

conveyances 

available for fuel 

supply. 



Technically feasible - 

a pipeline could be 

constructed and 

water rights may be 

available. 



Technically feasible, 

although there is not 

likely enough water 

consistently available 

from the Musselshell 

to make it a 

reasonable 

alternative water 



Require pipelines, 

pump stations, and 

easements 



Require pipelines, 

pump stations, and 

easements 



Technically feasible, 

although not enough 

water is likely 

available from the 

shallow acquiferto 

make it aq 

reasonable water 

source. 



Would require 

additional wells. 

Woulddrawdown 

local wells in the area 



Technically feasible, 
although this would 
increase the amount 
of water needed and 
would result in 
additional water 
resource impacts. 



Technically feasible, 
but not practical 
economically. 



Technically feasible. 



Would require 

different design and 
increase water use. 



Would require 

completely new 

facility design. This 

system would burn 

more coal for same 

MW output. 



Would require 
completely new 
facilty design. 



Cyclone and CFB 
boilers would be 

used to burn higher 

sulfur coal and use 
smaller boilers. 
Three CFB units 

would be needed. 

Solid waste would 
increase. 



Would require 

completely new 

facility design. This 

system would burn 

more coal for same 

MW output. 



Ecomonics of the 
facility dependent 
upon an abundant 
supply of coal in the 
mmediate vicinity as 
a mine-mouth project 



Ecomonics of the 

facility rely upon an 

abundant supply in 

the immediate 

vicinity, of which 

there are none. 



Ecomonics of the 

facility rely upon an 

abundant supply in 

the immediate 

vicinity, of which 

there are none. 



Ecomonics of the 

facility rely upon an 

abundant supply in 

the immediate 

vicinity, of which 

there are none. 



Ecomonics of the 
facility are infeasible 
and cost prohibitive. 



Would be much 
more expensive and 
would likely result in 

the costs being 
prohibitive. 



Would be more 
expensive due to 

conveyance costs. 
Also, insufficient 
supplies of water 

would be available. 



May or may not be 

more expensive, but 

supply is not likely to 

be sufficient. 



Cost of additional 

water could increase 

costs. 



More reasonable 

cost s but could not 

meet the expected 

outputs 



No data, but costs 

per MW output would 

be expected to 

substantially 

increase. 



No cost analyses 

were performed for 

these types of 

designs. 



Technically feasible 

in one of many 

different 

configurations being 

used around the 

country. 



Would require 

completely new 

facility design. No 

gas lines are within 

the area that could 

supply the fuel 

requirements. 

Facility would burn 

more gas for same 

MW output. 



No cost analyses 

were performed for 

these types of 

designs 



Other sites are not 
feasible in order to 
utilize Bull Mountain 

coal. 



Dewatering and 

treating. 



Waste streams 

would have to be 

separated and 

treated 



The handling 

logistics of 

transporting coal to 

another site would 

make the plan 
uneconomical and 
therefore infeasible. 



Other generation 
sites would not be as 

cost effective as a 

mine-mouth concept, 

and would therefore 

be infeasible. 



Would require adding 

slurry pipeline and 

pumps. 



Would require adding 

slurry pipeline and 

pumps. 



Process would 

include keeping 

bottom ash separate 

from the fly ash and 

flu gas wastes. 

Disposal would be 

segregated. 



Would not affect air 

emissions. Would 

require separate 

handling and 

segregated disposal, 

thus increasing 

costs. 



Would need to 
modify Waste Rock 

Repository to 
accommodate and 
isolate Ash Lens 



Would require 
additional permits. 



Would likely be 

difficult to 
accommodate waste 
disposal on-site for 
the life of the project 
due to limited space 

available. 



Would need to truck 

at least 20 loads of 

ash to waste rock 

area per day. 



TSDF construction. 



TSDF construction. 



Most economical, but 
water supply is an 
issue for this project. 



Most economical, but 
water supply is an 
issue for this project. 



Additional handling 

and segregated 

disposal would likely 

be somewhat more 

expensive. 



Assume costs are 
similar or somewhat 

higher because of 
additional logistics to 

coordinate waste 

rock and solid waste 

disposal. 



Would be more 
expensive because 

of handling and 
transportation costs. 



Would likely be more 
expensive for special 
design and handling 
to accommodate the 
solid waste on-site in 
limited space. 



> 


o 




















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K 


o 




O 



No expected 
changes in regulation 

except that new 
emission rates would 
have to be calculated 

and modeled 



No expected 
changes in regulation 

except that new 
emission rates would 
have to be calculated 

and modeled 



No expected 
changes in regulation 

except that new 
emission rates would 
have to be calculated 

and modeled 



No expected 
changes in regulation 

except that new 
emission rates would 
have to be calculated 

and modeled 



No regulations. 



Would require water 
right acquistion. 



Would require water 

right acquisition (e.g., 

purchase from 

irrigators). 



Would require water 
right acquistion. 
Also, insufficient 

supplies would likely 
be available on a 
consistent basis. 



Fugitive PM10 

emissions from wet 

cooling towers would 

have to be calculated 

and included in 

modeling analysis. 



No expected 
changes in regulation 

except that new 
emission rates would 
have to be calculated 

and modeled 



No expected 
changes in regulation 

except that new 
emission rates would 
have to be calculated 

and modeled 



No expected 
changes in regulation 

except that new 
emission rates would 
have to be calculated 

and modeled 



No expected 
changes in regulation 

except that new 
emission rates would 
have to be calculated 

and modeled 



Regulatory 

requirements could 

be somewhat 

different to 

accommodate 

transport of coal and 

water. 



Air permit would 
need to be modified. 



Air permit would 
need to be modified. 



Solid waste permit 

would need to be 

modified to 

accommodate 

logistics and handling 

with waste rock. 



Would have to 
modify permit to 
accommodate this 
type of disposal. 



TSDF permit. 



Would have to permit 
expanded facility to 
accommodate off- 
site disposal. 



3 
O 
tfl w 



O 
Q_ 



Similar to Proposed 
Action 



Similar to Proposed 
Action 



Similar to Proposed 
Action 



Similar to Proposed 
Action 



Water Resource 

impacts. Air impacts 

would be minimized 

or eliminated. 



Additional impacts to 
water resources, 

fisheries, and other 

resources from a 

pipeline. 



Additional impacts to 
water resources, 

fisheries, and other 
resources from a 

pipeline. 



Would likely result in 
impacts to wetlands 
and water resources, 
and could affect well 
production in the 
area. 



Additional impacts to 

water quality and 

quantity. 



Additional air, solids 
and water resource 
impacts would likely 

result. 



Additional air, solids 

and water resource 

impacts would likely 

result. 



Air emissions would 

likely be higher and 

solid wastes would 

be increased. 



Similar to Proposed 

Action after air 
quality mitigation. 



More impacts would 
result to air quality 

because of 

transportation costs 

for the fuel. 



Solid waste 
treatment would be 

more difficult and 
would result in more 

impacts to water 
quality and quanitity. 



Solid waste 
treatment would be 

more difficult and 
would result in more 

impacts to water 
quality and quanitity. 



Likely would result in 

similar impacts as 

the Proposed Action. 



Woufd increase size 

of Waste Rock 

Repository 



Could 
exposure to 
groundwater impacts 



Solid waste off-site 

would result in 

slightly higher 

environmental 

impacts, although 

waste stream not 

expected to have 

measurable effect on 

groundwater 

resources. 



_0J 



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.Q 



at 



Not reasonable 

because of fuel 

transportation costs, 

increased cost of 

logistics, and would 

not meet the purpose 

and need for the 

Proposed Action. 



Not economically 
feasible and would 
not meet the stated 
purpose and need for 
the Proposed Action 



Not economically 
feasible and would 
not meet the stated 
purpose and need for 
the Proposed Action 



Not economically 
feasible and would 
not meet the stated 
purpose and need for 
the Proposed Action 



Not economically 
feasible and would 
not meet the stated 
purpose and need for 
the Proposed Action 



Not reasonable 

because increased 

costs of pipeline and 

treatment would 

make the project 

infeasible. 



Not reasonable 

because of increased 

costs of pipeline and 

treatment, and 

insufficient water 

supplies available. 



Not reasonable 

because of 
insufficient water 
supplies available. 



Common design, but 

increase in water 
usage would result in 
higher construction 
and operation costs 
and increased water 
resources impacts. 
Alternative is not 
reasonable. 



Not reasonable 

because increased 

costs would make 

the project infeasible, 

thus not meeting the 

stated purpose and 

need. 



Not reasonable 

because increased 

costs would make 

the project infeasible, 

thus not meeting the 

stated purpose and 

need. 



Not reasonable 

because these boiler 

types are designed 

for different fuel not 

available at this 

location. 



Not reasonable 
because turbines are 
designed for different 

fuel and since 

adequate supplies of 

gas are not available, 

this alternative is not 

feasible. 



Would not 
reasonably meet the 
purpose and need for 
the Proposed Action 
because increased 
costs would make 
the project infeasible. 



Not reasonable since 
this technology woufd 
require additional 
water and would 
result in higher 
impacts to water 
resources. 



Not reasonable since 
this technology would 
require additional 
water and would 
result in higher 
impacts to water 
resources. 



Additional handling 

and segregated 
disposal would likely 
be somewhat more 
expensive, and was 

eliminated from 

further consideration 

because of increased 

costs and handling 

with no benefit. 



Not a reasonable 

alternative because 

additional logistics 

and costs with no 

benefit, and is 

considered and 

eliminated. 



Is not reasonable 

because increased 

costs would result in 

no benefit. 



Not reasonable 
because of space 



Table 2-2 Alternatives Comparison Summary 



Proposed Action 



Roundup Power Project, as proposed 



Waste Disposal Alternatives 



Proposed Action - Waste 
Disposal in Mine After 10 Years 



Alternative - Expand Landfill 

After 10 Years (Preferred 

Alternative) 



More information would be required for in- 

mine storage of waste ash with long-wall 

coal mining method. 



Designed same as Proposed Action 
landfill; 3 times larger landfill area 



Transmission System Alternatives 



Proposed Action - 3 Circuits of 
161 kV Transmission 



Alternative - Double Circuit 
230kV Transmission Line 



1 61 kV would require more circuits, 

shorter poles and shorter spans between 

poles than a higher voltage system to 

transport 750MW 



230kV would require fewer circuits and 
larger conductors, taller poles but wider 

spans between poles, and different 

hardware than a lower voltage system to 

transport 750MW 



No Action 



Generation facility would not be 

constructed or operated. Transmission 

System and Waste Storage proposed 

action or alternatives would not be 

constructed and operated. 



208 acres of ground disturbance. 



208 acres of ground disturbance 



Ground 
Disturbance 



Additional ~70 acres would be disturbed 

to develop the waste disposal landfill and 

the road 



Use existing roads; would need some 

new roads and upgrades to existing 

roads pending railroad spur construction; 

Ground disturbance on right-of-way (300 

feet x 28 miles) for structures and 

access roads; most disturbance 

temporary. 



Use existing roads; would need some 

new roads and upgrades to existing 

roads pending railroad spur construction; 

fewer circuits than lower voltage would 

require less labor and materials; Ground 

disturbance on right-of-way (300 feet x 

28 miles) for structures and access 
roads; most disturbance temporary; Less 

ground /•lie'ti irh^n^^ k^/'ni if ^ M f/Mt>^r 



Ground disturbance resulting from 

constructing and operating the generating 

facility and transmission lines would not 

occur. 



Water Resource 



(A 

+■» 
O 

re 
o. 

E 

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1_ 
3 
O 
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Earth Resources 



Biological and 
Wetland 



Impacts to ground water from in-mine 

storage of waste unknown; more studies 

would be required to assess impacts; zero 

discharge minimizes impacts on ground 

water resources from wastewater ponds 

and solid waste landfill 

Soil erosion impacts would be minimal due 

to control of runoff from the generation 

site. 



Loss of ~207 acres of grass/shrubland for 

wildlife habitat, grazing and agriculture; no 

impacts to T&E species 



Impacts unknown and will require 

additional investigation, however could 

include elevated concentrations of TDS 

and metals and impacts to spring and 

well production. 



Minor soil erosion would result from 

transport of waste from generating facility 

to mine site. 



No impacts to T&E species 



Similar to Proposed Action. 



Cultural Resource 



Archaeological site within the plant site 
would be impacted. 51 cultural resources 
within 3 miles of the 574-foot chimneys, of 
which 8 are considered visually sensitive. 



Solid waste disposal haul road and 

conveyor belt could potentially affect a 

prehistoric lithic scatter. 



Minor soil erosion would result from 

transport of waste from generating 

facility to expanded landfill site. 



Expanding the landfill would result in 

additional ~70 acres habitat loss. No 

impacts to T&E species 



Impacts would occur from access road 
construction, maintenance activities, and 

clearing of right-of-way, structure and 

work areas. Crosses several ephemeral 

drainages. No perennial streams 

crossed. Crosses the Hay Basin 

lakebed. 

Minor displacement of earth materials. 
Direct impacts to soils from access 
roads, and clearing of right-of-way, 
structure locations and work areas. 

No impacts to T&E species 



Similar to Proposed Action. 



Similar to the Proposed Action; slightly 

less because of fewer expected 

structures. 



No impacts to T&E species 



Water Resource impacts resulting from 

construction and operation of the 

generating facility and transmission lines 

would not occur. 



Earth Resource impacts resulting from 

construction and operation of the 

generating facility and transmission lines 

would not occur. 

Biological impacts resulting from 

construction and operation of the 

generating facility and transmission lines 

would not occur. 



Could have greater impacts than 

Proposed Action due to greater ground 

disturbance. 



Three cultural resources identified within 
or near transmission route. 



Similar to the Proposed Action, however 

the potential to disturb undiscovered 

resources may be slightly lower due to 

increased span length. 



Cultural Resource impacts resulting from 

construction and operation of the 

generating facility and transmission lines 

would not occur. 



Visual 



Visual impacts to residents and travelers 
from chimneys. 



Low to non-identifiable impacts. 



The expansion of the landfill would be 

more noticeable than the Proposed 

Action, but would result in only low visual 

resource impacts 



Visual impacts at road crossings and 

from scattered residences resulting from 

transmission lines. 



Similar to the Proposed Action - Visual 

impacts at road crossings and from 

scattered residences resulting from 

transmission lines. 



Visual impacts of constructing and 
operating the generating facility and 
transmission lines would not occur. 



Land Use 



Socioeconomic 
Benefits 



Conversion of currently available grazing 

and agricultural land to heavy industrial 

use. Recreation use at the plant site would 

be permanently lost. 

Full economic benefits realized from 

implementation of the Proposed Action, 

including tax benefits to Musselshell 

County and the State of Montana, jobs 

created during construction and during the 

life of the project to operate and maintain 

the generating facility and to mine the 

coal. 



Conversion of currently available grazing 

and agricultural land to heavy industrial 

use. Recreation use would be 

permanently lost 

Socioeconomic benefits would result from 
construction jobs, taxes for government 
agencies and social services, and long- 
term jobs from operation and 
maintenance of the facility. 



Similar to the Proposed Action. 



Similar to the Proposed Waste Disposal - 
Socioeconomic benefits would result 
from construction jobs, taxes for 
government agencies and social 
services, and long-term jobs from 
operation and maintenance of the 
facility. 



Crossing of non-irrigated cropland, 
livestock grazing land, and CRP land. 



Socioeconomic benefits would result 
from construction jobs, taxes for 
government agencies and social 
services, and long-term jobs from 
operation and maintenance of the 
facility. 



Similar to the Proposed Action. 



Similar to the Proposed Transmission 
Line System - Socioeconomic benefits 

would result from construction jobs, taxes 

for government agencies and social 

services, and long-term jobs from 

operation and maintenance of the facility. 



Existing land uses would continue. No 

impacts to land uses from the generating 

facility and transmission lines would occur. 

Musselshell County and the State of 

Montana would not gain the tax benefits, 

jobs, and other socioeconomic benefits 

from operating the generation facility and 

transmission line, and would not gain the 

jobs and economic benefits from operating 

the Bull Mountain Mine to support the fuel 

needs of the generating facility. 



Roundup Power Project 



Final Environmental Impact Statement 



CHAPTER 3 
SOURCES OF DEIS COMMENTS 

Table 3-1 Comments from Local, State and Federal Agencies and Tribes 



Comment Source 


Comment Numbers 


Local, State and Federal Agencies and Tribes (Refer to Appendix A for agency and 
Tribe letters) 


Alan Olson - Representative 
State House of Representatives 


8, 106 


Charles E. Matthews 

Process Manager, Network Planning 

Bonneville Power Administration 


142, 143 


Dan Martin, Planner 
Program & Policy Analysis Bureau 
Rail, Transit & planning Division 
Montana Department of Transportation 


102, 103 


Don Codding 

Air Resource Division 

Nation Park Service 


1,2,3,4,5, 12, 13, 19,33,39,79,80 


Geri Small, President 

Northern Cheyenne Tribe Administration 


14, 18,32,42,51,87,88 


James E. Reno, Commissioner 
Yellowstone County Commissioners 


31,93 


Kirby Danielson 
Subdivision & Planning 
Musselshell County 


94, 95, 96, 97, 98, 99, 100, 101 


Richard R. Long 
U.S. EPA Region VIII 


24, 25, 30, 37, 38, 47, 48, 49, 50, 53, 61, 62, 63, 64, 
65, 66, 67 


Stan Wilmoth, Ph.D. 

State Archaeologist/Deputy, SHPO 

State Historic Preservation Office 


108, 109, 110, 111 



Montana DEQ 



3-1 



Chapter 3 



Final Environmental Impact Statement 



Roundup Power Project 



Table 3-2 Comments from Private Citizens and Organizations 



Comment Source 


Comment Numbers 

"These comments are summarized from repeated topics. 


Private Citizens and Organizations 


Al Mills 


Lhank you for your remarks 


Alan W. Bndwell 


17* 


Alen Stoll 


Lhank you for your remarks 


Anita Joessmann 


Lhank you for your remarks 


Anne G. Charter, BMLOA Chair 

Bull Mountain Landowners Association 


23, 46, 60 


Ann Haggett 


85* 


Barbara Arms 


91, 105 


Barbara Yoder 


17* 


Berklee B. Cudmore 


Lhank you for your remarks 


Beslanowitch 


138 


Bette Lowery 


57 


Beverly M. and Robert C. Falsted 


Lhank you for your remarks 


Bob Stocker 


Lhank you for your remarks 


Bonnie E. Miller 


17* 


Carissa Hill 


Lhank you for your remarks 


Carol Guzman- Aspevig & Clyde Aspevig 


Lhank you for your remarks 


Carrie Atiyeh Kowalski 
Environmental Defense 


10, 1 1, 16, 22, 26, 36, 40, 41, 44, 45, 54, 52, 55, 59, 
91, 82, 83, 84, 85*, 107*, 1 13, 1 14, 1 15, 1 16, 1 17, 
123, 124, 125, 126, 127, 128, 129, 130, 131, 132, 133, 
134, 135, 136, 137, 139, 140 


Cecil Deming 


Lhank you for your remarks 


Chancie Myers 


Lhank you for your remarks 


Charlotte Trolinger 


17*, 85*, 107* 


Christine Caramanica 


Lhank you for your remarks 


Christopher Lish 


6, 107* 


Conrad E. Wickstrom 


17* 


Curtis & Los Cannell 


7 


Curtis Hahn 


17* 


Danny F. Siemers 


Lhank you for your remarks 


Dean Ruscoe 


107* 



Chapter 3 



3-2 



Montana DEQ 



Roundup Power Project 



Final Environmental Impact Statement 



Comment Source 


Comment Numbers 

'These comments are summarized from repeated topics. 


Private Citizens and Organizations 


Delores A. Poe 


17* 


Dennis Campbell 


Thank you for your remarks 


Dennis O'Reilly 


Thank you for your remarks 


Don Seyfert 


Thank you for your remarks 


Donna Luehrmann 


17* 


EJ Harpham 


Thank you for your remarks 


Elaine Rippey 


Thank you for your remarks 


Elizabeth Miles 


Thank you for your remarks 


Elizabeth Robinson 


17* 


Ellen Pfister 


29,43, 118, 119, 121 


Emily Metzgar 


17* 


Eric Guidry 

Energy Project Staff Attorney 

Land and Water Fund of the Rockies 


10, 1 1, 16, 22, 26, 36, 40, 41, 44, 45, 54, 52, 55, 59, 
91, 82, 83, 84, 85*, 107*, 1 13, 1 14, 1 15, 1 16, 1 17, 
123, 124, 125, 126, 127, 128, 129, 130, 131, 132, 133, 
134, 135, 136, 137, 139, 140 


Eran Holmes 


Thank you for your remarks 


Fred Bardelli 


Thank you for your remarks 


G. Todd Baugh 


Thank you for your remarks 


Garrett Sawyer 


17* 


Gavin Kramer 


Thank you for your remarks 


George Holton 


Thank you for your remarks 


Gray Harris 


27 


Gregory Wilhelmi 


Thank you for your remarks 


Group of Citizens of Montana: 

Patricia Borneman; Sandy Shull; Bruce H. Kershaw; 
Neil L. Perry; Brian Cooper; John R. Wulsin; 
Thomas G. Keith; Bill Borneman; Brenda Lochinton; 
Colette Strizils; Stanley A. Derensing; Irene N. Lee; 
Joseph Walden 


107* 


Harry Hardy 


17* 


Henry Dykema 


17* 


Herb Fobes 


Thank you for your remarks 


Hope Sieck 

Associate Program Director 

Greater Yellowstone Coalition 


10, 1 1, 16, 22, 26, 36, 40, 41, 44, 45, 54, 52, 55, 59, 
91, 82, 83, 84, 85*, 107*, 1 13, 1 14, 1 15, 1 16, 1 17, 
123, 124, 125, 126, 127, 128, 129, 130, 131, 132, 133 



Montana DEQ 



3-3 



Chapter 3 



Final Environmental Impact Statement 



Roundup Power Project 



Comment Source 


Comment Numbers 

"These comments are summarized from repeated topics. 


Private Citizens and Organizations 


Greater Yellowstone Coalition 


134, 135, 136, 137, 139, 140 


J. McKiely 


Thank you for your remarks 


James Barnett 


Thank you for your remarks 


James D. Greene & Martha A. Vogt 


85* 


James H. Meyers 


Thank you for your remarks 


Jean Vaira 


Thank you for your remarks 


Jeffrey J. Smith 


Thank you for your remarks 


Jerry Fraser 


9,92 


Jim & Marge O'Toole 


122, 133, 141 


Jim Emerson 


Thank you for your remarks 


Jim Mckowin 


Thank you for your remarks 


Joan Ryshavy 


Thank you for your remarks 


Joanne Bernard 


Thank you for your remarks 


Jocelyn G. Elson-Riggins, Ph.D. 


17* 


Joel G. Vignere 


107* 


John and Kathy Pritchard 


Thank you for your remarks 


John C. Hain 


Thank you for your remarks 


John L . Delano 


Thank you for your remarks 


Jonathan Lotz 


17* 


Judy Reed 


Thank you for your remarks 


Julie Bolcer 


Thank you for your remarks 


Kathie A. Bailey 


Thank you for your remarks 


Kelly Corley 

Yellowstone Valley Citizen's Council 


11, 17*, 23, 24, 31,37, 61, 133, 135, 137 


Kenneth M. Nevel 


17* 


Kip Gjerde 


28, 112 


Kip Drobish 
Raven Ridge Farm 


Thank you for your remarks 


Laine McNeil 


Thank you for your remarks 


Lavinia and Frank Reno 


Thank you for your remarks 


Lisa Discoe 


85* 


Lori Henderson 


85* 



Chapter 3 



3-4 



Montana DEQ 



Roundup Power Project 



Final Environmental Impact Statement 



Comment Source 


Comment Numbers 

'These comments are summarized from repeated topics. 


Private Citizens and Organizations 


Lorraine Kuntz 


17* 


Mack Cole 


Lhank you for your remarks 


Margaret J. Leverton 


Lhank you for your remarks 


Marian Lacklen 


Lhank you for your remarks 


Mark E. Juedman 


85* 


Marshal Compton 


17*, 107* 


Martin S. Cohen 


Lhank you for your remarks 


Mary Brower 


Lhank you for your remarks 


Michael Ford 


85* 


Mike Eiselein 


Lhank you for your remarks 


Mike Lulay 


Lhank you for your remarks 


Mike May 


17* 


Mike Yochim 


Lhank you for your remarks 


Mr. & Mrs. Donald D. Snow 


17* 


Mr. Donald G. Knauss 


Lhank you for your remarks 


Ms. Linda M Bonacci 


Lhank you for your remarks 


Ms. Sue Dickenson 


85* 


Nick Colder 


Lhank you for your remarks 


Patrick Judge 

Energy Policy Director 

MEIC 


10, 1 1, 16, 22, 26, 36, 40, 41, 44, 45, 54, 52, 55, 59, 
91, 82, 83, 84, 85*, 107*, 1 13, 1 14, 1 15, 1 16, 1 17, 
123, 124, 125, 126, 127, 128, 129, 130, 131, 132, 133, 
134, 135, 136, 137, 139, 140 


Paul Edwards 


Lhank you for your remarks 


Paul S. Kent & Bill Kent 


85* 


Peter Zadis 


17*, 107* 


Philip F. Richmond 


Lhank you for your remarks 


Ramona Clark 


17* 


Robert Oset 


Lhank you for your remarks 


Roberta Frasca 


Lhank you for your remarks 


Roger and Susan Sherman 


107* 


Ronm E. O'Neil 


85* 


Sara Loubman 


85* 



Montana DEQ 



3-5 



Chapter 3 



Final Environmental Impact Statement 



Roundup Power Project 



Comment Source 


Comment Numbers 

"These comments are summarized from repeated topics. 


Private Citizens and Organizations 


Shirley Wolters 


Thank you for your remarks 


Sonj a Indreland 


Thank you for your remarks 


Stan Everson 


Thank you for your remarks 


Steve and Judy Bayless 


Thank you for your remarks 


Steve Marquardt 


107* 


Terry Prichard & Nancy Mertz 


17* 


Terry Ross 

(CEED) Center for Energy & Economic 

Development 


15 


Tom McKerlick 


Thank you for your remarks 


Tony Jewett 

Senior Director, Northern Rockies Region 

National Parks Conservation Association 


10, 1 1, 16, 22, 26, 36, 40, 41, 44, 45, 54, 52, 55, 59, 
91, 82, 83, 84, 85*, 107*, 1 13, 1 14, 1 15, 1 16, 1 17, 
123, 124, 125, 126, 127, 128, 129, 130, 131, 132, 133, 
134, 135, 136, 137, 139, 140 


Vern Rich 


Thank you for your remarks 


Vickie Patton 
Senior Attorney 
Environmental Defense 


10, 1 1, 16, 22, 26, 36, 40, 41, 44, 45, 54, 52, 55, 59, 
91, 82, 83, 84, 85*, 107*, 1 13, 1 14, 1 15, 1 16, 1 17, 
123, 124, 125, 126, 127, 128, 129, 130, 131, 132, 133, 
134, 135, 136, 137, 139, 140 


Wade Sikorski, Ph.D. 


56 


Wendy Malmid 


107* 


Wilbur Wood 


17*, 34, 35, 58, 85*, 86 


William B. Hall 


17* 



Table 3-3 Comments from Project Proponent 



Project Proponent - Thank you for your remarks 



Steven T. Wade 

Browning, Kaleczyc, Berry & Hoven, P.C. 

Bull Mountain Development Corp., LLC 



20, 21, 68, 68, 70, 71, 72, 73, 74, 75, 76, 77, 78, 
90, 104 



Chapter 3 



3-6 



Montana DEQ 



Roundup Power Project 



Final Environmental Impact Statement 



Table 3-4 Comments from Roundup Power Project Public Hearing 



Oral Testimony from Public Hearing Dec 5, 2002 - Thank you for your remarks 


Alan Evans 


Kelly Gebhardt 


Bart Erickson 


Mack Cole 


Charles Heath 


Michael Lange 


Don Codding 


Monty Sealey 


Gary Mjolsness 


Paul Tarmann 


Gregory Wilhelm 


Philip Richmond 


Herb Fobes 


Ray Frasca 


Joe Dickey 


Victor De Maio 


John Ligget 





Table 3-5 Comments from Draft Permit Comment Period 



Publics and Agencies who commented on Draft Air Permit prior to DEIS 


Wilbur Wood 


34, 35, 58, 86 


Beslanowitch 


138 


Eric Guidry 

Energy Project Staff Attorney 

Land and Water Fund of the Rockies 


52,59,81-83, 139-140 


Vicki Patton 
Environmental Defense 


52,59,81-83, 139-140 


Patrick Judge 

Energy Policy Director 

MEIC 


52,59,81-83, 139-140 


Steven T. Wade 

Browning, Kaleczyc, Berry & Hoven, P.C. 

Bull Mountain Development Corp., LLC 


68-78 


Don Codding 

Air Resource Division 

Nation Park Service 


19,33,39,79-80 


Geri Small, President 

Northern Cheyenne Lribe Administration 


18,32,51 



Montana DEQ 



3-7 



Chapter 3 



Final Environmental Impact Statement 



Roundup Power Project 



Table 3-6 



Comments from Private Citizens via Email 



Private Citizens sent via E-mail - Thank you for your remarks 


Adam de Yong 


Adam Hill 


Adam Miller 


Adam Savett 


Adriana Francois 


Alan Seegert 


Alanna Louin 


Alex Herrera 


Alexandra Miles 


Alexia Dorsch 


Alexis Kenyon 


Alice Bartholomew 


Alice Benham 


Alice Neuhauser 


Alison McDowell 


Allen Altman 


Allen Church 


Allison Shurr 


Amanda Petel 


Amanda Poverchuk 


Amie Osowski 


Amy Brzeczek 


Amy Corley 


Amy R. Prisco 


Amy Schneider 


Ana Velasco 


Andrea Diephuis 


Andrew Freeman 


Andrew H. Card, Jr. 


Andy Lynn 


Angela Burbage 


Angela Hemingway 


Angela Jackson 


Angela Thompson 


Angie Grosland 


Angus Morrison 


Ann Hamilton & Ron Stirling 


Ann Marie Kotlik 


Ann R. Jacobson 


Annemarie Fitzell 


Annette Hagerty 


Annette Johnson 


Anthony DiLemme 


Anthony Donnici 


Anthony Nieter 


Antony DiGiovanni 


Archbishop Sergius 


Art Zernis 


AudnaLang 


August & Judith Mirabella 


Azel Beckner 


Barbara A. McClain 


Barbara Erb 


Barbara Hayward 


Barbara Schaeffer 


Barbara Yoder 


Barre Simmons 


Barry Allison 


BC Hall 


Becky Mailer 


Becky Russell 


Benjamin Coulter 


Benjamin Daniel 


Berklee B. Cudmore 


Bernie Sierelson 


Bert Smith 


Beth Brown 


Bethani Goste 


Betsy Robinson 


Betty Abel 


Betty J. Van Wicklen 


Betty Jean Herner 


Betty Lowery 


Betty Martin 


Betty Stephens 


Beverly Ackerman 


Beverly Drucker 


Billie Whittaker 


Bob Knapp 


Bob Thompson 


Bonnie New 


Brad Hutcheson 


Brain Stewart 


Brandy Hinkle 


Brenda Lehman 


Brenda Planchon 


Brent Rowley 


Brian Bockhahn 


Brian Coan 


Brian Lutenegger 


Brian Scott 


Brian Thomas 


Bridgit Roeth 


Brooke Livingston 


Bruce Acciavatti 


Bruce K. Mafarlane 



Chapter 3 



Montana DEQ 



Roundup Power Project 



Final Environmental Impact Statement 



Private Citizens sent via E-mail - Thank you for your remarks 


Bryan Roosien 


Bryan Strickland 


Bud Corely 


Burt Culver 


C. B. Pearson 


Caitlm O'Reilly 


Candace Dias 


Carissa Hill 


Carl Clark 


Carla Burgess 


Carla Winterbottom 


Carlos Moreno 


Carlton Swisher 


Carol Blumenthal 


Carol Liberatore 


Carol Linning 


Carol Oster 


Carol Pridgeon 


Carol Sulanke 


Carolyn Bourassa 


Carolyn Ganus 


Carolyn Miller 


Carolyn Mullin 


Carrie Atiyeh Kowalski 


Casper Nicca 


Catherine Knollmeyer 


Cathy Arnett 


Cathy Burleson 


Cedar Stanistreet 


Celeste Shitama 


Celine Nahas 


Chad Fordham 


Charlene Root 


Charles Ferris 


Charlotte Alexandre 


Charmaine Oakley 


Cheri Downen 


Cheryl Owens 


Cheryl Thacker 


Chris Henderson 


Chris Norbury 


Chris Palmer 


Christina Wilkins 


Christopher Lish 


Christopher Lukachko 


Christopher Mull 


Christy Carosella 


Christy George 


CJ Dupont 


Claire Langone 


Claire Mikalson 


Clarissa Confer 


Clark Andelin 


Clark Andelin 


Clyde Everton 


Clyde Remmers 


Colette Corwin 


Connie Adamski 


Connie Boitano 


Conrad E. Wickstrom 


Constance Chambers 


Constance L. Everitt 


Corinne Ebinger 


Courtney Gartin 


Craig Beach 


Craig Colistra 


Craig Conn 


Crystal Booth 


Cyndi Torelli 


Cynthia Ortiz 


Cyrstal Cain 


D Scott 


D.A.A1 95 Randall 


Dale & Sheree Kesler 


Dan and Janet Blair 


Dana Palka 


Dana Steeples 


Dana Suechting 


Dana Wullenwaber 


Daniel Hawley 


Danny Dillow 


Darlene Wolf 


Dave Easterday 


Dave Trochlell 


David & Diane Sonneville 


David & Nike Stevens 


David Anderson 


David Byman 


David DesRochers 


David Koltz 


David Lien 


David Mills 


David Nuckols 


David Roederer 


David Smith 


David Thompson 


David Wick 


David Wright 


David Yingling 


Dawn Powell 


Dean Griffin 


Dean Ruscoe 



Montana DEQ 



3-9 



Chapter 3 



Final Environmental Impact Statement 



Roundup Power Project 



Private Citizens sent via E-mail - Thank you for your remarks 


Deanna Gerwin 


Deanna Wenstrup 


Deb Klein 


Debbie Feldman 


Debbie Gibbs-Halm 


Debra Burns 


Debra Havill 


Debra Lakin 


Delia Prevele 


Delores A. Poe 


Demelza Costa 


Denise DeGeare 


Dennis B. Wolfe 


Dennis O'Reilly 


Diana Allard 


Diana Dexter 


Diana Wallace 


Diana Wittenbreder 


Diane Grinde 


Diane Hargreaves 


Diane Hert 


Diane Lucas 


Diane Pratzner 


Dianne Beal 


Dianne Brehmer 


Dianne Patterson 


Dick Paull 


Dolores C. Pino, Esq. 


Don & Pat Griffith 


Don Anderson 


Don Blanton 


Don Renninger 


Don Shepler 


Don Steinke 


Donna Calvao 


Donna Cooper 


Donna Deutsch 


Dora Anderson 


Doris Dickens 


Dorothy A. Roux 


Dorothy Buchholz 


Dorothy Hanes 


Dottie Moseley 


Doug Hilborn 


Douglas Adolphsen 


Douglas Bushey 


Douglas Harmsen 


Douglas Murray 


Duke Sharp 


Edward Petcavage 


Eileen Cox 


Eileen Levin 


Eileen Perry 


Eileen Smith 


EJ Harpham 


Elaine Fischer 


Eleanor Burian-Mohr 


Eliet Brookes 


Elinore Krell 


Elizabeth Case 


Elizabeth Dodd 


Elizabeth May 


Elizabeth Miles 


Elizabeth Mullen 


Elizabeth Olsson 


Elizabeth Petersen 


Ellen Kolasky 


Ellen Mongolis 


Elora Gabriel 


Elvira Floran-Bernier 


Ely nor Little Wolf 


Emily Johnson 


Emily Oesterling 


Emily Young 


Eric Dec 


Eric Holm 


Eric Krueger 


Eric Speed 


Erica Lee 


Erich Pessl 


Erik Schultz 


Erin Zell 


Ero Lippold 


Esther Cover 


Ethan Finkelstein 


Eugene Kiver 


Frances Cone 


Franchezska Zamora 


Franco Delucchi 


Frank Cassell 


Frank McNeely 


Frans de Calonne 


Fred J. Goebel 


Fritz Clark 


Fritz Wittenburg 


Gail Harmon 


Galen Davis 


Garret VanWart 


Gary Fishman 


Gary Thompson 


Gayle Spelts 


Gena Bukur 



Chapter 3 



3-10 



Montana DEQ 



Roundup Power Project 



Final Environmental Impact Statement 



Private Citizens sent via E-mail - Thank you for your remarks 


Gene & Doris Peters 


George Imrie 


George Moy 


Gerald J. Dalton 


Gerald Meslar 


Gerard Veraldi 


Gerrett Sawyer 


Gian Andrea Morresi 


Gideon Derr 


Gina Lopez 


Giuseppina Audisio 


Gloria Diggle 


Gloria Polis 


Grace Busch 


Grace Dion 


Greg Maloney 


Gregg Lustig 


Gregg Mau 


Gregory Esteve 


Gregory Kelly 


Hank Bourscheidt 


Harold Boyce 


Harriet Helman 


Harrison P. Bertram 


Harry Schueler, Jr. 


Harvey Picker 


Heather Best 


Heather Lingle 


Heather Rorer 


Heidi Gilbertson 


Heidi Long 


Helen Bratt 


Helen Bueker 


Helen Kopp 


Henry Dykema 


Herman Smith 


Hilda Kidwell 


Hiroko Jones 


Hosea McAdoo 


Hugh Brandon 


Ida Sheriff 


Ines Henzler 


J Jeffries 


J. Roberts 


Jack Herbert 


Jack Houghton 


Jackie Pomies 


Jacklyn Young 


Jacqueline French 


Jacqueline Lasahn 


Jake Hays 


James Andelin 


James Boone 


James Davidson 


James Facette 


James H. Meyers 


James Helm 


James Highfill 


James Hood 


James Lupo 


James McCarthy 


James Simmons 


James Ward 


James Williams 


Jamie Przybylski 


Jamie Silberberger 


Jan Clark 


Jan Galajda 


Jan Nissl 


Jane Wagner 


Janet Holly Romine 


Janet Nash 


Janet Rivers 


Janet Stuckrath 


Janet Wingard 


Janet Wyatt 


Janice VanDusen 


Janine Mahraun 


Janine Laulman 


Janis Boersma 


Jason Russ 


Jay and Sandy Lynch 


Jay Antol 


Jay Greene 


Jayne Ayers 


JC Burbank 


Jean Fox 


JeanLalande 


Jean Melom 


Jean Strickler 


Jean Workman 


Jeanette Vasko 


Jeanne DeGange 


Jeanne Leske 


Jeannette Bowman 


Jeff Stetz 


Jeminie Shell 


Jen Piercy 


Jenni Kovich 


Jennifer Berman 


Jennifer Clark 


Jennifer Gaudette 



Montana DEQ 



3-11 



Chapter 3 



Final Environmental Impact Statement 



Roundup Power Project 



Private Citizens sent via E-mail - Thank you for your remarks 


Jennifer Grande 


Jennifer Haun 


Jennifer Humowiecki 


Jennifer Kline 


Jennifer Lubinsky 


Jennifer Morgan 


Jennifer Parker 


Jennifer Wilder 


Jennifer Zavaleta 


Jenny Wilson 


Jerry Cormier 


Jerry Fraser 


Jesse Gore 


Jessica Gardetto 


Jill Forman 


Jill Quilici 


Jim and Jean Linos 


Jim Krebs 


Jim Mosser 


Jim Plezia 


Jim Stoltz 


Jimmy Malecki 


Jineen Griffith 


Jo Ellen Young 


Jo Lockwood 


Joan Book 


Joan Brieding 


Joan Larson 


Joan Marlatt 


Joan Ramsay 


Joanathan Fernsler 


Joanna Bagatta 


Joanna Lrainor 


Joanne Linden 


Joanne Smith-Hileman 


Jocelyn Elson-Riggins 


Jody Conrad 


Joel Layne 


John & Nancy Arnold 


John Barfield 


John Blouch 


John Booth 


John Buchanan 


John Caulkins 


John Fairfield 


John Miller 


John Pedersen 


John Petersen 


John Preudhomme 


John Randolph 


John Seider 


John Spanitz 


John Will 


Jon Maxwell 


Jon Schwedler 


Jonathan Lomber 


Jonathan Lotz 


Jonathan Matthews 


Jonathan Schwartz 


Josep+A490h Bail 


Joseph Blaszcsak 


Joseph Pedevill 


Joseph Vasko 


Joshua Lhompson 


Joshua Valencia 


Joyce Bowen 


Joyce Felter 


Joyce Harkness 


Judith Scher 


Judith Smith 


Judy Krach 


Judy Reed 


Judy Walker 


Judy Wexler 


Jules Gindraux 


Juli Ames-Curtis 


Julia Benedetti 


Julia Johns 


Julian Kesterson 


Julie Bolcer 


Julie Bond 


Julie Gambill 


Julie Rodgers 


Julie Laylor 


Justine Geiger 


Kai Chan 


Karen McConnell 


Karen Miles 


Karen Sanderson 


Karen Wills 


Kari Fickling 


Karl Peet 


Kate Marks 


Kate Richardson 


Katherine Feguer 


Kathie Finnell 


Kathleen Assiff 


Kathryn Miller 


Kathy Galligan 


Kathy Hamill 


Katie McCarthy 


Keegan Roberson 



Chapter 3 



3-12 



Montana DEQ 



Roundup Power Project 



Final Environmental Impact Statement 



Private Citizens sent via E-mail - Thank you for your remarks 


Keith Carlton 


Kelli Barber 


Kelly Corley 


Kelly Hanlon 


Kelly Sanchez 


Ken W. Bosworth 


Kenn Goldman 


Kenneth Albers 


Kent Dennison 


Kerrie Byrne 


Kerry Brukhardt 


Kerry Mitchell 


Kevin & Suzanne Flynn 


Kevin and Lracy Burgess 


Kevin Corcino 


Kevin Newman 


Kia Mintwoo 


Kim Goodwin 


Kim Kessler 


Kim Mazik 


Kim Olson 


Kimberly Clemens 


Kimberly Kennard 


Kimberly Pererson 


Kimberly Peterson 


Kimberly Schrader 


Kimberly Shaub 


Krista Kissner 


Kristen Green 


Kristin Painter 


Kristin Sumner 


Kristina Smucker 


Kristine Acevedo 


L. Emerson 


L. Janette Davie 


L. Sieffert 


Laine McNeil 


Lammie Chung 


Lanette Henderen 


Larry Hall 


Larry Johnson 


Laura & Brett Holmquist 


Laura Bauer 


Laura Bechdel 


Laura Eddy 


Laura Herndon 


Laura Jobe 


Laura Sproull 


Laurel Bellante 


Lauren Brown 


Lauren Libert Wells 


Laurie Fahrner 


Laurie Longtine 


Laurie Schreiber 


Lauryn Slotnick 


Lavinia & Frank Reno 


Lawrence Crowley 


Lawrence Hooker 


Lawrence Weirick 


LeAnne Paris 


Ledy VanKavage 


Lee Adrian 


Lee Home 


Lee Kimbrough 


Lee Kintzel 


Lee Winslow 


Lee Ann Bennett 


Leigh Griffing 


Lene Muller 


Lenore Rubino 


Lerayne Elliott 


Leslee Doner 


Leslie Harman 


Leslie Jane Johnston 


Leslie Smith 


Levi Cecil 


Lexie Praggastis 


Lillian Hanahan 


Linda Boy sen 


Linda Bridwell 


Linda C. Fowler 


Linda Capozzoli 


Linda Leblang 


Linda Lyerly 


Linda Naher 


Linda Werner 


Linda York 


Lindsay Johnson 


Lisa DeVaney 


Lisa Frey 


Lisa Hayes 


Lisa J. Discoe 


Lisa Marshall 


Lisa Slepetski 


Lisa Uchno 


Lisha Doucet 


Liz Lundholm 


Logadia Hennigar 


Lohrie MacDonald 


Lois Soloman 


Lonnie Clar 


Lore Matz 



Montana DEQ 



3-13 



Chapter 3 



Final Environmental Impact Statement 



Roundup Power Project 



Private Citizens sent via E-mail - Thank you for your remarks 


Lori Blauwet 


Lori Henderson 


Louis Rhodes 


LoWana Chandler 


Lrry Forrest 


Lucia Marano 


Lucille Whitlark 


Lyle McRae 


Lyn Benedict 


Lynda Capps 


Lynda Matusek 


Lynn Dodson 


Lynn Fleischer 


Lynn Harrigan 


Lynn Meier 


M.O. Lawrence 


Mac Blewer 


Mack Grubb 


Madeline Yamate 


Marc Fleisher 


Marcia Bailey 


Marcia Peterson 


Marcia Watts 


Marcus Lanskey 


Margaret Allman 


Margaret Clay 


Margaret Rydant 


Maria Difiore 


Maria Lynn Therese 


Marian Simmons 


Marie Collins 


Marie Mark 


Marie Wilson 


Marilyn Edlund 


Marilyn Jasoni 


Marilyn McKinney 


Mark Bender 


Mark E. Juedeman 


Mark Roberston 


Marlena Lange 


Marta Moreira 


Martha Bushnell 


Martha Foster 


Martha Hogarth 


Martha Waltman 


Martie Crone 


Martin Baskin 


Martin Walls 


Marty Howe 


Mary Ann McFarland 


Mary C. Weatjerwax 


Mary Cherry 


Mary E. Halpin 


Mary Gail Decker 


Mary Inman 


Mary Knotts 


Mary Krouth 


Mary Mather 


Mary Nolly 


Mary Owens 


Mary Parker 


Mary Senecal 


Mary -Ellen Perry 


Matt Riggs 


Matthew Cozzi 


Matthew Jones 


Melanie Bratt 


Melisa Holman 


Melissa Chisena 


Melissa Judge 


Melissa McClaran 


Melody Madden 


Meredith Hariton 


Meredith Wietzke 


Merrill Cole, Ph.D. 


Michael Allen 


Michael Bailey 


Michael Culock 


Michael Dillman 


Michael J. Nally, Ph.D. 


Michael Kelly 


Michael Letendre 


Michael Nelson 


Michael Reynolds 


Michael Schmotzer 


Michael Welker 


Michele Johnson 


Michelle Bratt 


Michelle Gerson 


Michelle Mink 


Mikasa Moss 


Mike Bertram 


Mike Carte MD 


Mike Chowla 


Mike May 


Mike Sexton 


Mike Suzuki 


Mike Yochim 


Mikki Chalker 


Mimi McMillen 


Misti Jancosek 


Misty Levis 



Chapter 3 



3-14 



Montana DEQ 



Roundup Power Project 



Final Environmental Impact Statement 



Private Citizens sent via E-mail - Thank you for your remarks 


Mitch Cholewa 


Mo Attar 


Morris B. Miller 


Mr. & Mrs. Donald Wool 


Mr. Dante Joseph 


Ms. Nicholas Stockham 


Myrna Dantes 


Nancy Allison 


Nancy Crom 


Nancy Miller 


Nancy Zalewski 


Nandita Shah 


Nannette Cherry 


Naomi Oster 


Nathanael Brown 


Neil Milani 


Nichole Long 


Nichole Lorusso 


Nils Osterberg 


Nita Lowndes 


Nobuku Relnick 


Norman Goss 


Norman Kopecky 


0. Bisogno Scotti 


Olivia Zivney 


Pamela Dugan 


Pamela Duncan 


Pamela Jiranek 


Pamela Ohman 


Pandora Rose 


Pat Bergie 


Pat LeBaron 


Patricia Coffey 


Patricia Hopkins 


Patricia J. Jennings 


Patricia Maddox 


Patricia Simmons 


Patricia Youngson 


Patrick and Christi Loper 


Patrick Guilfoyle 


Patrick Kilbane 


Patrick Lunceford 


Patty Bartlett 


Paul Borokhov 


Paul Buechler 


Paul Chandler 


Paul Clark 


Paul Edwards 


Paul Hunt 


Paul Paine 


Paul Sieg 


Paul Szymanowski 


Paula Aydt 


Paula Cooley 


Paula Dee 


Paula Scheuering 


Paula Wilson-Cazier 


Pedro Urionabarrentxea 


Peggy-Jo Schulte 


Pete Anderson 


Pete Falc 


Peter Zadis 


Philip Gargiulo 


Philip Hult 


Phillip Smith 


Phoebe Blanchford 


Priscilla Mattison 


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Montana DEQ 



3-15 



Chapter 3 



Final Environmental Impact Statement 



Roundup Power Project 



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3-16 



Montana DEQ 



Roundup Power Project 



Final Environmental Impact Statement 



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Montana DEQ 



3-17 



Chapter 3 



Roundup Power Project Final Environmental Impact Statement 

CHAPTER 4 
COMMENTS AND RESPONSES ON THE DEIS 

Air Visibility 

1 . A significant reduction in visibility would hinder the benefits and enjoyment of 
visitors to Yellowstone National Park and UL Bend WA . . . Visibility impacts from 
the RPP alone would cause a significant change in extinction that would hinder the 
benefits and enjoyment of visitors to Yellowstone National Park and UL Bend WA 
on the days those impacts occur. The emissions from RPP would significantly 
contribute to the more frequent and severe cumulative visibility impacts that occur at 
both Yellowstone National Park and UL Bend WA. 

Response: 

DEQ agrees that a significant reduction in visibility would be unacceptable. 
However, the question remains as to whether or not the Project would cause a 
significant reduction in visibility. Currently, DEQ is analyzing the case-by-case 
analysis of the days of impact, the FLAG guidance document, and the applicable 
federal and state rules to determine whether or not the Project may cause or 
contribute to an adverse impact to Class I areas. A case-by-case analysis was 
submitted by the Project Proponent to more closely analyze the days that the 
model predicted an impact. The analysis takes into consideration the actual 
weather occurrences for the days that indicate visibility impacts greater than 
5%. By rule, the Department may not issue a final air quality permit if 
impairment may result. However, DEQ may issue a final air quality permit if 
DEQ determines that the visibility analysis does not demonstrate that an 
adverse impact on visibility will result. DEQ's final decision on the visibility 
issue will be described in the ROD and will affect DEQ's decision to either issue 
or deny the Project a final air quality permit. 

2. RPP and the MT DEQ have raised the issue as to whether RPP' s contribution to the 
adverse cumulative visibility impacts are "significant" A review of the modeling 
outputs for the 1990 RPP-only and for the 1990 cumulative visibility impacts was 
done by the NPS/FWS (National Park Service/US Fish and Wildlife Service) to 
examine this issue. The results demonstrate that RPP's contributions on days in which 
the cumulative impacts exceed 10% at Yellowstone National Park and UL Bend WA 
are indeed significant. For instance, on Day #15 at receptor #33, the cumulative 
change in extinction is 12.24%. On that same day and at the same receptor, the 
change in extinction caused by RPP alone is 6.77% or 55% of the total cumulative 
visibility impact. On Day #16 at receptor #33, the cumulative change in extinction is 
14.32%. The extinction caused by RPP alone on this date and receptor is 6.33%, 
representing 44% of the cumulative visibility impact. Similarly, for UL Bend WA on 
day #46 at receptor #351, RPP's contribution was 8.41% of the total 29.18% change 
in extinction (29%). Our review of both the 1990 and 1992 results shows many 
additional instances when RPP represents a significant percentage of a cumulative 

Montana DEQ 4-1 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



change in extinction that is greater than 10% change in extinction at Yellowstone 
National Park and UL Bend WA. 

Response: 

See response to Comment #1. 

3. This determination must be made on a case-by-case basis taking into account the 
geographic extent intensity, duration, frequency and time of visibility impairments 
and how these factors correlate with (1) times of visitor use of the Class I area, and 
(2) the frequency and timing of natural conditions that reduce visibility. 

Response: 

See response to Comment #1. 

4. The Administrative Rules of Montana also give a similar definition, stating that 
"adverse impact on visibility means visibility impairment which the department 
determines does or is likely to interfere with the management, protection, 
preservation, or enjoyment of the visual experience of visitors within a federal Class I 
area. 

Response: 

See response to Comment #1. 

5. With respect to the relationship of visibility impact and time of visitor use of the 
Class I areas, Yellowstone National Park and UL Bend WA are both open to visitor 
use 24 hours a day, year-round. Thus visitation can and does occur at any time. There 
were nearly three million recreational visits to Yellowstone National Park during 
2001. For many visitors this is a once-in-a-lifetime experience, and the NPS and FWS 
are greatly concerned that the experience of each and every visitor not be interfered 
with by adverse visibility impairment on any day(s) in which visitation occurs. 
Regarding natural conditions that reduce visibility, RPP has stated that the 1990 
impact that is greater than 10% occurs during a snowstorm and that a park visitor 1) 
would not be out in the elements to view the scenery with any expectation of seeing 
vast distances and 2) the natural background impairment of the snowstorm would far 
outweigh the impact of RPP (October 21, 2002, letter to D. Walsh, MT DEQ, from 
J.W. Dickey). This argument is flawed because it assumes that the snowstorm would 
be occurring throughout the entire 1.1 million hectare area of Yellowstone National 
Park, and would affect all visitors present in the park at that time. Further, it is 
unlikely that this weather condition would persist throughout the entire period that is 
modeled. 

Response: 

The FLAG document describes that the determination on visibility impact 
should take into consideration, on a case-by-case basis, the geographic extent, 
intensity, duration, frequency and time of visibility impairments, and how these 
factors correlate with (1) times of visitor use of the Class I area, and (2) the 
frequency and timing of the natural conditions that reduce visibility. DEQ will 
take this guidance statement into consideration when determining the 
magnitude of the Project impact on visibility. 

Chapter 4 4-2 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



6. The National Park Service modeled visibility impacts for the park, which as a Class I 
airshed is supposed to have the cleanest air in the nation. Their analysis of the 
cumulative effect of Roundup with other nearby polluting sources demonstrates a 
reduction of over 10 percent visibility on 24 days annually-an enormous number in 
the scope of impacts within Class I airsheds. The Billings Gazette recently reported 
the National Park Service, U.S. Fish and Wildlife Service, and U.S. Forest Service 
have expressed concern about the potential for pollution from the plant causing 
visibility problems at Yellowstone National Park, UL Bend National Wildlife Refuge 
in north-central Montana, and in the North Absaroka Wilderness Area. 

Response: 

The FLMs have expressed great concern with impacts from the Project at the 
Class I areas. DEQ takes the NPS concerns seriously; however, a case-by-case 
analysis of the days that indicated visibility impacts greater than 5% from the 
Project indicates that the severity of the initial modeling results may have been 
overestimated. DEQ has yet to determine if the Project may cause or contribute 
to an adverse impact at any of the Class I areas and is currently analyzing the 
case-by-case analysis submitted to DEQ by the Project Proponent. See response 
to Comment #1 for further information. 

7. According to the National Parks Conservation Association, the cumulative effect of 
the Roundup Power Project along with other nearby sources of pollution 
demonstrates a reduction of over 10% visibility on 24 days annually. Additionally, 
the cumulative impacts to visibility at Yellowstone National Park from the proposed 
Roundup Power Project and other nearby sources is 39 days greater than the five 
percent reduction and 24 days greater than the 10 percent reduction. Because of the 
nearby Class I air sheds, including Yellowstone National Park, we feel this is 
unacceptable and must be addressed. 

Response: 

See responses to Comments #1 and #6. 

8. As for the visibility concerns of the Federal Land Managers addressed on pages 4-103 
and Appendix B-4, B-7, 1 have to question why the Federal Land Managers's would 
include air quality data from sources that no longer exist such as the Anaconda 
Smelter. 

Response: 

Such a question is more appropriately answered by the FLMs. However, DEQ 
intends to make a determination on the appropriate scenario for conducting the 
cumulative visibility analysis (as the analyses are described in Appendix B of the 
DEIS). The decision made by DEQ will be consistent with the applicable air 
quality rules. 

9. The Cumulative Visibility Analysis results should not be based upon emission data of 
major sources, with no decrease adjustment, from the PSD baseline data of 1975. 
Either a more recent baseline year should be used or both increase and decrease 
adjustments should be included. The modeling assesses air quality impacts by doing a 
"cumulative" visibility analysis. If one or more of the major sources no longer exists, 

Montana DEQ 4-3 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 

their emissions should not be included in the baseline, because of the effect on 
"cumulative" results. The visibility analysis would likely not show nearly as many 
days of 5% or more Class I exceedences. 

Response: 

See response to Comment #8. 

10. Roundup will have an adverse impact on visibility at Yellowstone National Park, and 
the UL Bend WA and North Absaroka Wilderness Areas. The state may not issue the 
air quality permit until these adverse effects are addressed. Montana has a Legal Duty 
to Consider the Cumulative Visibility Effects of Roundup in Conjunction with Other 
Emitting and Expected Pollution Sources. 

Response: 

See responses to Comments #1 and #6. 

1 1 . The Federal Land Managers' Modeling Analysis Documents Roundup's Adverse 
Visibility Impact, and Roundup's Alternative Visibility Analysis Reproduced Under 
DEIS Scenario Nos. 1 and 3 Are Seriously Flawed. 

Response: 

DEQ does not believe that any of the three visibility modeling scenarios are 
necessarily flawed. The FLAG document does not recommend a specific 
modeling protocol to determine the cumulative visibility impacts; therefore, the 
three different scenarios were examined. Each if the three scenarios has its own 
merits. Also see response to Comment # 6. 

12. The Federal Land Managers finding of an adverse impact is based upon a 
demonstration that the current or predicted deterioration of air quality will diminish 
the area's national significance, impair the structure and functioning of the area's 
ecosystem, or impair the quality of the visitor experience in the area. Modeling results 
presented in the RPP PSD application and in the DEIS (based on 1990 data) show one 
day exceeding a 10% change in extinction and seven days greater than 5% change in 
visibility extinction at Yellowstone National Park. Four days exceed a 5% change in 
extinction at UL Bend WA. Further modeling by RPP and NPS/FWS using 1992 data 
show two days at Yellowstone National Park and four days at UL Bend WA 
exceeding a 10% change in extinction. Thirteen and sixteen days exceed 5% change 
in extinction at Yellowstone National Park and UL Bend WA, respectively. The 
results of the cumulative visibility analysis (both 1990 and 1992 data) indicate that 
the RPP would be a significant contributing source to adverse visibility impacts at 
Yellowstone National Park and UL Bend WA. The values represented in all analyses 
(whether RPP-only or cumulative) predict impacts that would be perceptible to 
visitors at Yellowstone National Park and UL Bend WA, and would violate two of 
the three adverse impact criteria cited above (i.e., impair the visitor's experience and 
diminish the area's national significance). 



Chapter 4 4-4 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



Response: 

The analysis conducted up to the issuance of the DEIS did not include a specific 
case-by-case analysis of the days of impact shown by CALPUFF. Since the 
DEIS, the Project Proponent has submitted a case-by-case analysis of the days in 
question. See responses to Comments #1 and #6. 

13. The NPS and FWS have concluded that Roundup Power Project alone would cause 
an adverse impact to visibility at Yellowstone National Park and UL Bend WA, and 
contribute significantly to a cumulative adverse impact on visibility at Yellowstone 
National Park and UL Bend WA. This finding is clearly supported by language found 
in the Clean Air Act, Code of Federal Regulations, Administrative Rules of Montana 
and in the enabling legislation that established Yellowstone National Park. Therefore, 
we ask that the MT DEQ not grant a final PSD permit to RPP until our adverse 
impact concerns are adequately addressed. 

Response: 

See responses to Comments #1 and #6. 

14. ... The tribe believes, too, that up to date modeling with current sources be done to 
show the cumulative effects that impact the Northern Cheyenne Reservations. 

Response: 

Up-to-date modeling was performed to determine the impacts to the Northern 
Cheyenne lands. The results are contained in Appendix B of the DEIS. 

15. In this case, the applicant and the Department have demonstrated compliance with all 
of the applicable NAAQS and PSD increments. The NPS/FWS have not 
demonstrated that the proposed facility will have an adverse impact on an AQRV. 
Further, no Federal Land Managers demonstration has been submitted that provides 
proof not merely of a speculative risk of harm, but of demonstrable harm to an AQRV 
caused by the pollution from the proposed new source. In the absence of utilizing that 
lawful and available approach, the NPS/FWS should not be allowed to require 
continuous assessments and studies using questionable, non-peer reviewed and non- 
regulatory criteria such as those contained in the FLAG documents. 

Response: 

See responses to Comments #1 and #6. 

16. MDEQ did not examine mitigating Roundup's adverse impacts on Class I areas 
through emission offsets at Colstrip or Other Area Pollution Sources as recommend 
by EPA. 

Response: 

DEQ has yet to determine whether or not the Project may cause or contribute to 
adverse impacts on visibility in the surrounding Class I areas. DEQ does not 
have the authority in this permitting action to require emission offsets at 
Colstrip Units 3 and 4, which were permitted by the EPA, or other area 
pollution sources. If there is a problem with other emission sources, the 
appropriate course of action would be for the FLMs to certify visibility 

Montana DEQ 4-5 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



impairment. By certifying such impairment to EPA, other programs could be 
used to rectify problems created by existing sources. 

17. ...I am particularly concerned about the impact of this proposed power plant on the air 
quality around Yellowstone National Park, a Class I airshed. 

Response: 

The Project would not cause or contribute to a violation of any ambient air 
quality standard in or near Yellowstone National Park. However, DEQ is 
analyzing whether the Project may cause or contribute to an adverse impact on 
visibility within Yellowstone. See response to Comment #1. 

18. Visibility is another issue that needs to be addressed (on the Northern Cheyenne 
Reservation). Nitrogen dioxide greatly impairs visibility with the brown haze 
associated with it. 

Response: 

The visibility impacts from the proposed Project on the Northern Cheyenne 
lands were presented in the DEIS. Case-by-case factors may also influence the 
days of modeled impact for the Northern Cheyenne lands. The Project 
Proponent was required to conduct Class I visibility modeling for the nearby 
mandatory federal Class I areas, as required by Montana's rules. Since the 
Northern Cheyenne Reservation is not a mandatory federal Class I area, the 
Class I visibility modeling was not required as part of the New Source Review 
permitting process. However, as part of the EIS process, the Project Proponent 
was required to address impacts from the Project and cumulative impacts of the 
Project with other nearby sources on the Northern Cheyenne Reservation. The 
modeled impacts on the Northern Cheyenne lands were presented for 
informational purposes, but according to the regulations, cannot be used to 
accept or reject a permit application or to dictate permit conditions. 

19. A cumulative analysis of visibility impacts is necessary. 

Response: 

A cumulative Class I visibility analysis was submitted to DEQ and the FLMs. 
The analysis was discussed by the FLMs, DEQ, and the Proponent. The 
information from this analysis has been included in the EIS. 

20. Although the coal-fired power plant emissions would be higher from an existing 
plant, or roughly the same from a new plant at another location, additional emissions 
would result from the transportation necessary to ship the coal to its user. Additional 
emissions would result from the diesel-powered trains hauling the coal out of 
Montana. Pollutants from rail transport have been estimated for the approximately 
214 trains per year that would be necessary to haul the 2.7 million tons of coal out of 
state. We have estimated that exporting the coal to the Montana border then burning it 
at a similar new facility would result in total criteria pollutants of 1 1 1% of the 
Project's total pollutants, and NOx emissions. Similar emission increases would occur 
for all other emission products. 



Chapter 4 4-6 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



Response: 

The DEIS did not evaluate the impacts of burning Bull Mountain coal in other 
locations or for other projects. The objective of this Project is to combust the 
Bull Mountain coal at the Project facility, not at another facility. Conducting an 
analysis of the impacts from combusting coal at another location is outside the 
scope of this Project. The impacts from transporting coal to other areas were 
assessed in the Bull Mountain EIS (1992). 

2 1 . The visibility analysis results for Roundup Power Proj ect impacts (Table 4- 1 0) 

showed nine days of greater than 5% impact in Yellowstone National Park, based on 
CALPUFF modeling using 1990 meteorological data. Review of IMPROVE 
monitoring data from Yellowstone for 1990 (direct measurement of light extinction), 
which was used to determine the background conditions in the CALPUFF model, 
reveals that on six of the nine specific days for which Roundup impacts were 
predicted, 12 or more hours of visibility data were considered "invalid" by the NPS 
due to occurrence of precipitation and/or very high relative humidity. On two 
additional >5% impact days, six or more hours of data were considered to be invalid 
because of natural meteorological conditions. The invalid days included the day of 
highest predicted impact, when 18 of the 24 hours reported precipitation. Similar 
results were found for 1992 CALPUFF modeling results; out of 15 days of modeled 
5% or greater impact, actual Yellowstone visibility was considered to be impacted by 
natural conditions for nine or more hours on 12 days. These comparisons support the 
assertion that actual impacts to visibility will not occur on most of the days of model- 
predicted visibility degradation. . . . 

Response: 

See responses to Comments #1 and #6. 



Modeling 



22. The modeling analysis for Roundup is technically flawed. Roundup Failed to Include 
All Appropriate Sources in its Class I Modeling Analyses for Increments and 
Visibility Impacts Such as the Massive Oil and Gas Development Planned for 
Montana and Wyoming, and the YELP Facility. Roundup did not include all 
appropriate sources in its Class I modeling analysis for increments and visibility 
impacts. It appears that the modeling analysis did not consider the massive oil and gas 
development planned for Montana and Wyoming. Roundup also failed to include SO2 
emissions from the Yellowstone Energy Limited Partnership (YELP) facility and 
other sources listed in Table B-l of Appendix B. Specifically, Table B-l lists the 
increment consuming S0 2 emissions of the YELP facility as zero, as well as for 
"Williston Basin, EB" and "Colorado Inter., EB." 

Response: 

DEQ does not agree that the modeling analysis is technically flawed. The 
Proponent did in fact include all of the increment-consuming sources in its Class 
I Modeling Analyses for Increments and Visibility. The YELP facility does not 
consume increment. When YELP was permitted, S0 2 offsets were obtained 



Montana DEQ 4-7 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



from the Billings Exxon Refinery. Also, the Williston Basin, EB and Colorado 
Inter, EB facilities are compressor stations with negligible S0 2 emissions. Thus, 
DEQ believes all increment-consuming sources have been appropriately 
included in the analyses. 

While it is correct that the modeling analysis did not consider the massive oil 
and gas development planned for Montana and Wyoming, it would not have 
been appropriate to require analyses based on future development that may or 
may not occur. The Coal Bed Methane programmatic EIS under the BLM's 
lead has included emissions from the proposed Project along with other recently 
permitted facilities. The Project Proponent is not required to include speculative 
development plans in their modeling analysis. 

23. The EIS should include a detailed discussion of power plant air pollution's impact on 
human health and agricultural productivity. It should also include an economic 
analysis of the value of full enforcement of "Best Available Control Technology 
(BACT)" requirements. 

Response: 

The EIS does include an analysis on human health by showing that the ambient 
impacts from the Project's air emissions would be below the National Ambient 
Air Quality Standards (NAAQS) and the Montana Ambient Air Quality 
Standards (MAAQS). The NAAQS/MAAQS are set at levels that are intended to 
protect human health and the environment, with a margin of safety. The AQRV 
analysis in the EIS shows the impacts from air emissions (gaseous and trace 
metals) on sensitive species of plants, animals and soils. (See Section 4.2 of 
DEIS.) 

The BACT analysis that was provided by the Proponent in the air quality 
permit application and reviewed by DEQ includes an economic evaluation of all 
proposed pollution control equipment. The Proponent has included additional 
economic evaluations in response to requests by DEQ for additional information 
needed for BACT determinations. For instances where the top control 
technology was proposed and selected, a cost per ton of reduction was not 
necessarily figured because it did not factor into the BACT decision. 

All final BACT determinations summarized in the DEIS were completed using 
the top-down method outlined in the EPA New Source Review Manual. This 
method uses economic evaluations, collateral environmental damage 
assessments, and other appropriate criteria for determining BACT. 

24. a) In the draft EIS, cumulative modeled impacts predict that the 3-hour and 24-hour 
S02 Class I increments are exceeded in the NCIR Class I area (see Table B-2 of the 
draft EIS). Under our stated policies, if the Project's modeled contribution is 
significant, then it would appear that the permit should not be issued without further 
control or offsets. See 40 CFR 51.166(k); pages C.52 and C.53 of EPA's October 
1990 New Source Review Workshop Manual; EPA's July 5, 1998Memorandum from 
Gerald A. Emison, Director, OAQPS, to Thomas J. Maslany, entitled: "Air Quality 
Analysis for Prevention of Significant Deterioration (PSD)." 



Chapter 4 4-8 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



b) Presently, our regulations establish no set values for significant impacts on Class I 
increment, and to our knowledge, the Montana SIP does not establish values for 
significance for such impacts either. In concluding in the draft EIS that the Roundup 
Project would not be a significant contributor to increment exceedances in the NCIR 
Class I area, it appears that the State has assumed that Class I significance levels EPA 
proposed in 1996 as part of the NSR reforms proposal (published in the Federal 
Register on July 23, 1996 - 61 FR 38250) are appropriate. It would be helpful if you 
could confirm that this is the approach you are using and your basis for concluding 
that these values represent an appropriate significance threshold for evaluating 
impacts on Class I increment. 

Response: 

a) The predicted 3-hour and 24-hour S02 Class I increments are exceeded in the 
NCIR Class I area as a result of Colstrip Units 3 and 4. The Project does not 
cause or contribute to a violation of the Class I increments. As stated on page 
C.52 of EPA's October 1990 New Source Review Workshop Manual, "The 
source will not be considered to cause or contribute to a violation if its own 
impact is not significant at any violating receptor at the time of each predicted 
violation." The Project Proponent has made this demonstration through the 
cumulative Class I increment analysis. 

b) DEQ has not established any set values for significant impacts on Class I 
increment nor does the Montana SIP establish values for significant impact. By 
policy, DEQ uses the 40 CFR 51, Appendix S, values to determine significance 
(i.e., whether sources locating in unclassifiable areas would cause or contribute 
to a violation). Because the Project emissions would be above the Appendix S 
significance levels, a cumulative Class I increment analysis was performed to 
ensure that the Class I increments would not be violated as a result of the 
Project. The modeling showed that the Project would not cause or contribute to 
any Class I increment violation. The EPA-proposed, but not adopted, PSD 
significance levels are 4% of the Class I increments. 

25 In addition, we note that the modeled values for the Project are just under the 
significance levels for Class I increment used in the draft EIS. Under the 
circumstances, we believe it is important to carefully verify these modeled values and 
to correct any deficiencies in the modeling. For example, it appears that the predicted 
increment exceedances were based on the CALPUFF model being used for all 
sources near and far to the Class I area. This is not the correct regulatory approach for 
sources near the Class I area. Rather, the correct regulatory modeling approach would 
be to use CALPUFF for sources greater than 50 kilometers from the Class I area and 
ISC for sources less than 50 kilometers from the Class I area. Also, as we describe in 
greater detail elsewhere in this letter, it appears you may have underestimated 
emissions from the auxiliary boilers and other sources in your modeling, and we are 
unable to determine whether modeled values for the main boilers represent worst-case 
emissions on a 3-hour and 24-hour basis. 

Response: 

DEQ believes the correct approach for modeling all sources was used. While 
Colstrip Units 3 and 4 and Rocky Mountain Power are within 50 km of the Class 



Montana DEQ 4-9 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



I areas, all of the other sources are not, including the Project. It was concluded 
that the cumulative impact modeling results would be most valid if all modeling 
was performed with the same model, rather than mixing model results from two 
different models. Therefore, CALPUFF was the model of choice. Furthermore, 
DEQ already knows the violations on the NCIR border occur by modeling only 
Colstrip Units 3 and 4 using the ISC model. DEQ believes using CALPUFF is 
the correct approach. 

26. The air quality permit for Roundup must be denied unless the source mitigates the 
violations of the SO2 increment at the Northern Cheyenne Class I area. 

Response: 

See response to Comment #16. 

27. The draft EIS admits that estimated SO2 impacts for the Project "exceed PSD 
modeling significance levels" (p. 4-15), and estimated cumulative impacts "are above 
the PSD modeling significance levels" (p. 4-101). The conclusion that no impacts 
would be felt further than 8.1 miles away from the project is hogwash: 

Response: 

The DEIS did not state that no impacts would occur further away than 8.1 
miles. Table 4-9 states that the radius of impact for the PSD modeling 
significance level of 5 |ng/m 3 extends to 8.1 miles from the facility. Table 4-9 lists 
the distance, in miles, to the farthest point (i.e., receptor) at which the radius of 
impact level of 5 |^g/m 3 for the 24-hour averaging period is reached. 

28. While I could reasonably live with 'Low' impact severity, I can not accept 'Moderate' 
and 'High' impact severities to Montana's air resources as indicated on Table 4-18. 
The project needs to be reformulated such that all impact severities are 'Low'. The 
resulting alternative should then be adopted as the DEQ Preferred Alternative. 

Response: 

Table 4-18 was developed to summarize the potential impacts to air resources 
from the proposed action and the alternatives. Impact severity was defined as 
Low, Moderate and High. Low impacts indicated that the Project's modeled 
emissions were below screening thresholds, while Moderate indicated that the 
modeled emissions were above the screening thresholds. High indicated that the 
modeled emissions were near the standards. The standards were not exceeded in 
any case but the impact severity table was developed to show how close the 
modeled emissions were to the ambient standards or Class I/II increments. DEQ 
does not have the authority to deny an air quality permit based upon emissions 
that would be within lawful limits. 

29. According to the EIS, there is an area 8.5 miles in radius from the RPP that will suffer 
a higher deposition of pollutants. See Exhibit "B" attached hereto. I would like to see 
a lot more detailed discussion of what we who live within that radius or own land 
within it can expect as affects to us. 



Chapter 4 4-10 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 

Response: 

The 8.1-mile reference is used to identify how far the radius of impact for the 
PSD modeling significance level of 5 u.g/m3 for a 24-hour period extends from 
the facility. People living within the area or owning land will be impacted by the 
Project to some degree. However, the modeling has demonstrated that all 
ambient standards would be met. The ambient standards are set to be protective 
of human health and the environment. 

30. In Table 5-7 (page 50 of the permit application) and Table 4-38 (page 4-99 of the 
draft EIS), it does not appear that the flare emission limits from the Billings/Laurel 
sources were considered in the NAAQS/MAAQS modeling; the limits shown appear 
to be only the limits from the Billings/Laurel S0 2 State Implementation plan (SIP). 
The flare limits must be considered in the NAAQS/MAAQS modeling. 

Response: 

The flare emissions were erroneously left out of the model. These limits are 150 
lb/3-hr each for Montana Sulphur, Exxon, Cenex, and Conoco. Because the flare 
limits for Billings/Laurel are not included in the SIP submitted to EPA but are 
state-only enforceable limits, they were inadvertently left out of the model. The 
emissions entered into the model were 33,311 lb/3-hr; thus, the total emissions 
were underestimated by 600 lb/3-hr or 1.8%. However, this fact makes little 
difference in the final outcome of the modeling. For instance the 1-hour high- 
second-high modeled concentration is 480 |J.g/m 3 , the background concentration 
is 41.6 |»ig/m 3 for a total concentration of 522 |a,g/m 3 . Assuming the modeled 
results were scaled to account for this omission the difference would be 
negligible at less than 3 (a,g/m 3 . The one-hour MAAQS is 1300 |a,g/m 3 . 

3 1 . The predominant wind direction for this region is from the Southwest. The possible 
decrease in visibility to Yellowstone National Park is misrepresented. 

Response: 

Even though the predominant wind direction is from the southwest, visibility 
impacts are calculated on a 24-hour average. Therefore, the predominant wind 
direction has little effect when calculating maximum daily visibility impacts. As 
long as the wind direction is toward Yellowstone National Park during any 24- 
hr period (i.e., midnight to midnight), visibility impacts can occur at 
Yellowstone National Park. 

32. The Northern Cheyenne Indian Reservation is a redesignated Class I airshed. 
According to our wind data the prevailing winds are from the northwest. There are 
over twenty years of air quality data on the reservation. The site of the power plant is 
approximately 100 miles to the northwest of the reservation. Any impacts from this 
source, such as sulfur dioxide and nitrogen dioxide, would impact the increment 
concerning the Class I status. 

Response: 

The Proponent conducted air-modeling analyses to identify the potential 
impacts from the Project on the air quality at the Northern Cheyenne 
Reservation. The analyses were conducted to identify the potential impacts at 



Montana DEQ 4-11 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



the Northern Cheyenne boundary. DEQ has used the information to describe 
potential impacts in the DEIS. 

33. A cumulative SO2 increment analysis is necessary. 

Response: 

A cumulative Class I S0 2 increment analysis has been submitted and discussed 
by the Federal Land Managers, DEQ, and the Proponent. The information from 
this analysis has been included in the DEIS. 

34. We already have a local problem when one considers cumulative effects from 
emissions from the nearby petroleum and other refineries in Laurel, Billings, and 
Lockwood, just 35 miles to the south. 

Response: 

The applicable air quality rules and regulations require that the Proponent 
consider emissions from other sources in the modeling analyses. The Proponent 
conducted the analyses (including other emitting sources as appropriate), and 
DEQ reviewed the analyses to determine the accuracy and adequacy of the 
modeling that were conducted. Based on the modeling impacts from the Project 
and other nearby sources, the proposed Project would comply with the 
applicable air quality rules, regulations, and standards as required for permit 
issuance. 

35. The Department needs to consider the cumulative effects (from all of the new and 
proposed power plants in Montana) of carbon dioxide and other greenhouse gases and 
pollutants and particulates that are inevitably released into Montana skies. 

Response: 

Only emissions from the recently permitted Rocky Mountain Generation facility 
were included in the cumulative modeling analysis. Other recently permitted 
sources, such as Montana First Megawatts Plant, Silver Bow Generation Plant, 
and Thompson River Cogeneration Plant, were not included in the cumulative 
modeling analysis because they are all located at distances greater than 200 km 
from the Project. DEQ determined that the impacts from sources this far away 
would not be significant. Furthermore, carbon dioxide and other greenhouse 
gases are not regulated air pollutants under the federal or state regulations, so 
cumulative effects from carbon dioxide were not analyzed. 

Short-Term Emission Rates 

36. Roundup Failed to Model Maximum Short-Term Emission Rates for SO2. 

Response: 

Maximum short-term emission rates for S0 2 were modeled for all short-term 
modeling analyses (i.e., ambient standards, PSD increments, and AQRV). DEQ 
will include short-term S0 2 emission limits in the final air quality permit, if one 
is issued. All final decisions will be provided in the ROD. 



Chapter 4 4-12 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



37. Currently the draft permit only contains SO2 emission limitations on a 30-day rolling 
average. This approach may be acceptable only if modeling for protection of the 
short-term NAAQS and PSD increments was based on worst-case hourly S0 2 
emissions, rather than on the 30-day emission limitations in the draft permit. Based 
on the information we've received, we cannot tell whether worst-case hourly 
conditions were modeled. Table 4-8 (page 4-13) of the draft EIS indicates the hourly 
lb/hr limits and annual lb/hr limits were modeled. The document does not clearly 
explain what the hourly lb/hr limits are based on; there are no such limits in the draft 
permit. For example, are these levels based on the source's maximum potential to 
emit? 

At a minimum, we believe that the permit action should either establish short-term 
emission limits in the permit itself, or justify that worst-case hourly SO2 emission 
limits have been modeled for protection of short-term NAAQS and PSD increments. 
Our preference would be that the permit itself include the worst-case modeled hourly 
SO2 emission limits, in addition to the 30-day BACT limits. 

Response: 

See response to Comment #36. 

38. The NO x emission limits in the draft permit are expressed on a rolling 30-day 
average, but we do not see this as an issue for protection of NAAQS and PSD 
increments, because of the NO x NAAQS and increment are annual averages. 
However, we do support the comment that the National Park Services made in its 
August 27, 2002 letter to Dan Walsh, that an equivalent 24-hour limit be set for NO x 
to control short-term impacts upon visibility. 

Response: 

Maximum short-term emission rates for NOx were modeled for all short-term 
modeling analyses (i.e., ambient standards, PSD increments, and AQRV). DEQ 
will include short-term NOx emission limits in the final air quality permit, if one 
is issued. 

39. The Preliminary Determination on Permit Application does not set a limit on boiler 
heat input (except for tons of coal per year), nor are there any short-term emission 
limits for various pollutants. There are no limits at all for H2SO4. The lack of short- 
term (e.g., 3-hr and 24-hr) limits is especially problematic because the applicant has 
proposed to "overfire" the boilers for short periods, thus resulting in abnormally high 
emissions. These higher emission rates increase the possibility that AQRVs at 
Yellowstone NP and UL Bend WA could be adversely impacted. Therefore, we ask 
that MT DEQ include short-term limits for all pollutants in the final permit. It is also 
important that these rates correspond to those modeled in the air quality permit 
impact analysis. 

Response: 

Maximum short-term emission rates for S0 2 were modeled for all short-term 
modeling analyses (i.e., ambient standards, PSD increments, and AQRV). DEQ 
will include short-term S0 2 and NOx emission limits in the final air quality 



Montana DEQ 4-13 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



permit, if one is issued. DEQ will review the need to include a limit on boiler 
heat input. 

DEQ is currently discussing the applicability of an H 2 S0 4 limit. If DEQ decides 
to establish a limit for H 2 S0 4 , the limit will be included in the final air quality 
permit, if one is issued. Such a decision will be based upon what other recently 
permitted similar sources have been required to do. 

Meteorological Data 

40. Use of Billings Meteorological Data Without Consideration of Local Data Is 
Technically Flawed. 

Response: 

The Proponent consulted with DEQ prior to conducting any modeling. DEQ 
agreed that Billings' meteorological data would be considered representative. 
The EPA New Source Review workshop manual states that site-specific 
meteorological data is preferred for air quality modeling analyses if one or more 
years of quality assured data are available. However, if at least one year of site- 
specific data is not available, five years of meteorological data from the nearest 
National Weather Service station can be used in the modeling analysis. 

41 . Roundup Failed to Use the Most Recent Five Years of Meteorological Data. 

Response: 

The Proponent used five years of surface meteorological data (1987-1991) 
collected at the Billings International Airport National Weather Station and the 
corresponding upper air data collected at the Great Falls International Airport 
National Weather Station. These five years of data represent the most readily 
available processed data and were approved by DEQ. 

42. Page 4-5, 4.2. 1 : Paragraph number 4 and 5: Acid rain has been known to form miles 
downwind of a coal fired power plant. We have over twenty years of met data on the 
Northern Cheyenne Reservation. The prevailing winds are from the west, northwest 
and north, therefore the reservation would be impacted from RPP. 

Response: 

Although not performed for the Northern Cheyenne Indian Reservation, acid 
deposition from nitrogen and sulfur compounds was calculated for the UL Bend 
WA, Yellowstone National Park, North Absaroka WA, and numerous areas in 
the Beartooth Wilderness near Yellowstone National Park. Only the receptor at 
the UL Bend WA showed acid deposition slightly above the Data Analysis 
Thresholds (DAT) established by the Federal Land Managers. (See Table 4.12 of 
the DEIS.) The data supplied in the DEIS indicates that the acid deposition from 
the Project, which includes wet "acid rain" and dry deposition, would not 
greatly impact the Northern Cheyenne Indian Reservation. 

43. A little more recent weather data is in order for both Billings and RPP. See Exhibit 
"A-l" for an indicator map of where pollution from the RPP will enter the 
Yellowstone Valley according to the Mine wind rose. 



Chapter 4 4-14 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



Response: 

Even if more recent weather data or onsite data (assuming it is PSD modeling- 
worthy) are used in the PSD modeling analysis, maximum 3-hour and 24-hour 
impact values will probably not significantly change. Annual impacts based on a 
different predominant wind direction will shift with the wind direction, but the 
annual model-predicted impacts in the Yellowstone Valley are quite low and 
shifts in predominant wind directions will not cause significantly larger impacts 
in the Yellowstone Valley. 

Best Available Control Technology (BACT) 

44. Federal and state clean air laws, and MEPA require Montana to consider available 

methods - including IGCC - to lower airborne contaminants from Roundup. IGCC is 
available and must be considered in the BACT Analysis. 

Response: 

DEQ has followed all federal regulations, state regulations, and EPA- 
recommended guidance in the evaluation of BACT. Even though evaluating 
other types of power facilities is out of scope for a BACT analysis, DEQ has 
examined IGCC facilities. Based on information submitted by the Project 
Proponent and research by DEQ, DEQ determined that IGCC is not a viable 
option for the Project. 

45 The proposed SO2 and PM emission limits for Roundup fail to meet Wyoming's 
recent BACT determination for the WYGEN 2 facility. 

Response: 

When the draft air quality permit and DEIS were issued, the WYGEN 2 facility 
had not yet been permitted. Now that WYGEN2 has been permitted, DEQ will 
consider the determination made for WYGEN2 in the BACT determination. 
The final determinations on this issue will be described in the ROD and in a 
final air quality permit, if one is issued. 

46. Montana should follow the lead of other states by rejecting the applicants' pulverized 
coal plant design and directing them to evaluate an Integrated Gasification Combined 
Cycle alternative under the "Best Available Control Technology (BACT) national 
standard. 

Response: 

See response to Comment #44. 

47. The draft permit specifies 0.015 lb/MMBru as BACT, based on use of a baghouse. 
We believe 0.012 lb/MMBtu or lower should be specified as BACT. A BACT 
determination of 0.012 was recently made by the Wyoming DEQ for the WYGEN2 
project, a 500MW PC-fired boiler to be constructed by Black Hills Corporation. 
Wyoming's determination was based on use of a baghouse with membrane-type bags 
(e.g., Gortex). 

Response: 



Montana DEQ 4-15 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



See response to Comment #45. 

48. BACT in terms of lb/MMBtu. The draft permit specifies 0. 12 lb/MMBtu (on a 30-day 
rolling average) as BACT, based on use of a dry SO2 scrubber and assuming 94% 
control efficiency and worst-case coal sulfur content (equivalent to 1.90 lb/MMBtu as 
the scrubber inlet). We [EPA] believe a much tighter lb/MMBtu limit should be 
specified as BACT, for the following reasons: . . . 

Response: 

DEQ has followed all federal regulations and state regulations in the evaluation 
of BACT. DEQ is continuing to analyze other recently permitted similar sources 
as part of the ultimate BACT determination. The final BACT determination will 
be consistent with the applicable air quality rules. DEQ's final decision will be 
described in the ROD. 

49. BACT in terms of control efficiency. A minimum required SO2 scrubber efficiency 
should be included in the permit, to ensure proper operation and maintenance of the 
scrubber, and to ensure that SO2 emissions are minimized at all times, regardless of 
the sulfur content in the coal. Because of the severe visibility impacts identified by 
the Federal land manager, we believe the permit should specify scrubber efficiency in 
the range of 94% to 96% (on a 30-day rolling average), with compliance to be 
demonstrated via SO2, CEMS at the scrubber inlet and outlet. We note that 40CFR 
60.47a(b)(I) already requires inlet and outlet CEMS. We consider 96% efficiency 
achievable based in part on BACT determinations by other states (mentioned above), 
and on vendor literature from Babcock and Wilcox (a manufacturer of large PC-fired 
boilers and control equipment; see www.babcock.com ), which indicates that even 
higher S0 2 control efficiencies of 96% to 98% can be achieved with dry scrubbers, 
even where low-sulfur western coal is used. 

Response: 

DEQ is continuing to review the BACT analysis. Emission control efficiency 
requirements are typically not the result of BACT analyses. However, DEQ will 
review this suggestion in the context of the BACT determination. The final 
BACT determination will be consistent with the applicable air quality rules and 
recently permitted similar sources. The visibility impacts identified by the FLMs 
are a separate issue than BACT. The visibility issue cannot be used to establish 
the BACT determination. See response to Comment #48. 

50. The draft permit specifies 0.07 lb/MMBtu (on a 30-day rolling average) as BACT, 
based on combined use of low- NO x burners (LNB), selective catalytic reduction 
(SCR) at 80% control efficiency, and overfire air (OF A). The Montana DEQ's 
discussion of available control technologies of NO x fails to mention ultra-low- NO x , 
burners (ULNB). Vendor literature from Babcock and Wilcox (see 
www.babcock.com) indicates that the ULNB, in conjunction with 90% efficient SCR, 
could achieve NO x emission rates in the range of 0.015 to 0.025 lb/MMBtu. 

Response: 



Chapter 4 4-16 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



DEQ has followed all federal regulations and state regulations in the evaluation 
of BACT. DEQ is continuing to review the NOx BACT analysis. DEQ's final 
decisions will be described in the ROD. 

51. It is very important that BACT be implement in the operation of RPP. 

Response: 

DEQ has reviewed the BACT analysis that was submitted by the Proponent. In 
addition, DEQ has 1) researched other BACT determinations made throughout 
the nation, 2) reviewed current BACT proposals in other areas, and 3) discussed 
BACT proposals with other state and federal agencies. As required by rule, the 
BACT determinations were made taking into consideration energy, 
environmental, and economic impacts and other costs. Based upon this BACT 
review, DEQ determined that the BACT conditions contained in the Preliminary 
Determination were appropriate. Since the issuance of the preliminary 
determination, other BACT determinations have been made. DEQ is currently 
reviewing the BACT determinations. The final BACT determinations will be 
discussed in the ROD. 

52. BACT Determination 

a. MTDEQ' s Preliminary Determination for the Roundup Power Proj ect Fails to 
Satisfy the Core Requirements of a BACT Determination 

Response: 

DEQ disagrees with the assertion that the preliminary determination fails to 
satisfy the core requirements of a BACT analysis. DEQ believes that the analysis 
conducted for the preliminary determination completely satisfies the core 
requirements of a BACT analysis. 

b. IGCC is a Weil-Established Technology with Significant Emission 
Reductions Benefits that must be Considered as Part of the BACT Analysis. 

Response: 

The governing air quality regulations and supporting policy/guidance make it 
clear that BACT determinations are not a basis for redefining a project. 
Requiring the Proponent to install IGCC as part of the BACT determination 
would clearly redefine the Project. The appropriate control technologies were 
analyzed for the Project. 

c. Circulating Fluidized Bed Combustion is a Weil-Established Technology with 
Significant Emissions Reductions Benefits that Must be Considered as Part of 
the BACT Analysis 

Response: 

The administrative record shows that DEQ not only considered circulating 
fluidized bed (CFB) boilers, but DEQ requested more information on this issue 
from the Proponent. Based on information submitted by the Proponent to DEQ 
and research by DEQ, DEQ determined that CFB boilers did not constitute 
BACT. 



Montana DEQ 4-17 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 

d. The Proposed SO2 Emission Limitation Does Not Reflect BACT 

Response: 

DEQ is continuing to review the S0 2 BACT determination. Additional BACT 
information has become available since the preliminary determination was 
issued. DEQ's final BACT determination will be described in the ROD. 

e. The BACT Analysis Fails to Adequately Consider Circulating Dry Scrubber 
Technology 

Response: 

Circulating Dry Scrubber (CDS) technology was adequately analyzed as part of 
the S0 2 BACT analysis. The Project's initial air quality permit application 
included an evaluation of the CDS technology. DEQ requested more information 
on CDS technology from the Proponent. Based on this information and DEQ 
research, DEQ determined that CDS technology does not constitute BACT 

f. The Draft Permit Fails to Impose an Emission Limitation Representative of 
BACT for Sulfuric Acid Mist 

Response: 

DEQ is currently considering a sulfuric acid mist limit for the Project. Any final 
decisions will be included in the final air quality permit, if one is issued. 

g. The Proposed PM10 Emission Limit Does Not Reflect BACT. 

Response: 

DEQ is currently considering revising the PM U emission limit for the Project. 
Any final decisions will be included in the final air quality permit, if one is 
issued. 

h. MTDEQ Has Failed to Specify a Visible Emission Limitation Representative 
of BACT 

Response: 

DEQ does not believe a 5% opacity limit is necessary or constitutes BACT. The 
definition of BACT in the state regulations allows the establishment of a visible 
emission limit in lieu of an emission limit if necessary. The definition does not 
indicate that a visible emission limit must be established as part of the BACT 
determination. The opacity limit of 20% will remain in the final air quality 
permit, if one is issued. 

Maximum Achievable Control Technology (MACT) 

53. The project is subject to case-by-case MACT pursuant to section 122(g) of the Clean 
Air Act. However, Montana DEQ did not establish case-by-case MACT limits or 
follow the procedures specified in the Administrative Rules of Montana (ARM)) 
17.8.342 or 40 CFR §63. 43(c) Review options, (f) Administrative procedures for 



Chapter 4 4-18 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



review of the Notice of MACT Approval (g) Notice of MACT Approval and (h) 
Opportunity for public comment on the Notice of the MACT Approval. 1 

Response: 

DEQ concurs that the Project is subject to case-by-case MACT requirements 
under state and federal regulations. The procedures for completing a case-by- 
case MACT given in ARM 17.8.342 and 40 CFR 63.43 will be followed in 
completing a MACT determination (notice of approval or disapproval) prior to 
beginning actual construction of the Project or in conjunction with issuance of 
the final air quality pre-construction permit. 

54. MDEQ must establish emission limitations for mercury and other HAPS to be 
discharged from the Roundup Power Plant as required by federal and state law. 

Response: 

DEQ is responsible for implementing requirements for control of hazardous air 
pollutants (HAPs) from new major sources of HAPs, as described in the 
response to Comment #53. ARM 17.8.342 stipulates that a new major source of 
HAPs must obtain a notice of MACT (maximum achievable control technology) 
approval prior to beginning actual construction. The MACT determination for 
newly constructed major sources is governed by requirements in 40 CFR 63.43; 
the determination results in a MACT emission limitation or requirement which 
shall not be less stringent than the emission control which is achieved in practice 
by the best controlled similar source. 

A specific design, equipment, work practice or operational standard, or a 
combination thereof may be substituted for an emissions limit if DEQ 
specifically determines that it is not feasible to prescribe or enforce an emission 
limitation under the criteria set forth in section 112(h)(2) of the Federal Clean 
Air Act [40 CFR 63.43(d)(3)]. 

55. Mercury has serious, adverse impacts on public health and the environment. MDEQ 
must establish rigorous Hg emission limitations for Roundup to ensure protection of 
public health and the environment. 

Response: 

See response to Comment #54. 

56. An increase in mercury exposure across all of southeastern Montana is unacceptable 
to me. 

Response: 

See response to Comment #54. 

57. What of mercury byproducts? 

Response: 

When coal is burned in a boiler, mercury is converted to elemental mercury 
vapor (HgO) in the high temperature regions of combustion devices. As the flue 
gas cools, HgO is oxidized to ionic mercury (Hg++). In coal-fired combustors, 
HgO may be oxidized to mercuric oxide (HgO), mercuric sulfate (HgS0 4 ), 

Montana DEQ 4-19 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



mercuric chloride (Hg Cl 2 ), or some other mercury compound (EPA-600/R-00- 
083). HgO, Hg Cl 2 , and HgO can adhere to porous solids such as fly ash, 
powdered activated carbon, and calcium-based acid gas sorbents for subsequent 
collection in a particulate matter control device. 

Once in the atmosphere, mercury exists in either the elemental vapor or ionic 
form (EPA-600/R-00-083). Most of the mercury in the atmosphere is elemental 
mercury vapor and inorganic mercury; most of the mercury in water, soil, 
plants and animals is inorganic and organic mercury (primarily 
methylmercury) (EPA-823-F-01 -01 1 ). 

Methylmercury is the most common organic form of mercury and is easily 
absorbed into the living tissue of aquatic organisms and is not easily eliminated. 
Therefore, it accumulates in predators. The degree to which mercury is 
transformed into methylmercury and transferred up the food chain through 
bioaccumulation depends on many site-specific factors (such as water chemistry 
and the complexity of the food web) through processes that are not completely 
understood (EPA-823-F-01-001). Methylmercury is highly toxic to mammals, 
including people, and causes a number of adverse effects. EPA has established a 
criterion of 0.3 mg methylmercury/kg in fish tissue that should not be exceeded 
to protect the health of consumers of noncommercial freshwater/estuarine fish. 
EPA has developed a quantitative model relating air deposition of mercury to 
accumulation of methylmercury in fish. EPA is also developing procedures to 
translate methylmercury concentrations in fish to total mercury concentrations 
in ambient surface water. 

58. Mercury emissions were not addressed at all. 
Response: 

See response to Comment #57. 

59. The draft Roundup permit fails to include MACT emission limitations. 

1 . Roundup' s Permit Application Fails to Adequately Address Case-By-Case 
MACT Application Requirements 

Response: 

See response to Comment #53. 

2. The Mercury MACT Emission Limit for Roundup Should Be Based on 
Ninety Percent Reduction Achievable with Activated Carbon Injection 

Response: 

See responses to Comments #53 and #54. 

Draft Air Quality Permitting Issues 

60. The EIS and air pollution permitting process should be suspended pending 
demonstration by the applicant of serious intention to commence construction with 12 
months of permitting. 



Chapter 4 4-20 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



Response: 

Federal PSD regulations state that a facility must commence construction within 
18 months of the final permit being issued or BACT would have to be 
reevaluated before construction can commence. Currently, the Preliminary 
Determination of the Project air quality permit states that the Project 
Proponent must commence construction within 3 years. However, DEQ may 
change this requirement to 18 months. Any final decisions will be in the ROD, 
and if issued, the final air quality permit. 

61 . EPA has not approved into the SIP the de minimis permitting provisions mentions in 
section II. C. 2. We believe section II. C. 2 should be removed from the permit. 

Response: 

State regulations allow for de minimis changes. The regulations apply to sources 
applying for an air quality permit in Montana. 

62. The draft permit only requires a stack test once every five years for NOx and S0 2 
emissions from the auxiliary boilers. We do not believe this is adequate to 
demonstrate continuous compliance with the emission limitations in lbs/hr. For S0 2 , 
the permit should also require record keeping for sulfur content in the fuel oil burned, 
the quantity of fuel oil burned per hour, and the resulting S0 2 emission rate in lb/hr. 
For NOx, the permit should require annual stack tests, unless test results are 
sufficiently below the emission limitation that test frequency can be reduced to once 
every five years. 

Response: 

DEQ is examining the testing schedules and record keeping requirements 
contained in the draft air quality permit. DEQ's internal testing guidance and 
the use of CEMS will affect the ultimate decision on testing frequency. DEQ's 
final decisions will be discussed in the ROD and in the final air quality permit, if 
issued. 

63. We have several questions with respect to the PMio, SOx and NOx emission 
calculations on pages 23 and 24 of the draft permit and the provisions in sections 
II. A. 13 through 17 and 19. 

1) First, section II. A. 16 limits diesel consumption of the two auxiliary boilers to 
5,438,400 gallons per rolling 12-month period and section II.A. 17 limits the 
combined hours of operation of the two auxiliary boilers to 3,300 hours per rolling 
12-month period. If you divide total oil consumed by total hours of operation 
(5,438,400/3,300) you would consume 1,648 gallons/hr. Yet the calculations on pages 

23 and 24 assume that 823 gals/hr of oil are used. The calculations on pages 23 and 

24 of the draft permit and the emission calculations for the auxiliary boilers in 
Appendix B2 of the permit application seem to imply that the fuel oil consumption 
for auxiliary boilers will be around 2,766,000 or 2,716,000 gallons year, respectively. 
We question whether the limit in section II.A. 16 was developed in error. If not, we 
question why 823 gal/hr was used in calculations on pages 23 and 24. 



Montana DEQ 4-21 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



2) Second, the limit in section II. A. 13 is not consistent with the calculations on pages 
23 and 24 of the draft permit. The calculations in the draft permit indicated that 
emissions would be 64.61 lbs of S0 2 /yr, yet section II. A. 13 has a limit of 6.46 lbs of 
SCVhr. It appears that the limit in section II. A. 13 is incorrect. The permit application 
also appears to indicate that 6.47 lbs of S0 2 /hr was used in the permit modeling. 

3) Third, the limit in section II. A. 19 is not consistent with the calculations on pages 
23 and 24 of the permit. Section II. A. 19 indicates that the sulfur content of the No. 2 
fuel oil used in the auxiliary boilers shall not exceed 0.05%, yet the calculations on 
pages 23 and 24 indicate that the sulfur content on the fuel oil is 0.5%. Perry's 
Chemical Engineer's Handbook indicates that No. 2 fuel oil contains 0.5% sulfur (see 
1984 edition, pages 9-10 to 9-???). We question whether the limit in section II. A. 19 is 
correct. We also believe that section II. A. 19 should be rewritten to make it clear that 
only No. 2 fuel oil or better can be burned in the auxiliary boilers. Finally, we note 
that the permit limit for sulfur content in fuel oil needs to be at least as stringent as the 
1 lb of sulfur per mmBTU fired limit required by ARM 17.8.322(4). 

Response: 

The request for corrections to the Preliminary Determination of the Project air 
quality permit will be examined by DEQ. If warranted, the changes will be made 
in the final air quality permit, if issued. 

64. Section III.H of the permit indicates that construction must begin within 3 years of 
permit issuance and proceed with due diligence until the project is completed or the 
permit revoked. We believe this is an unreasonably long period of time before 
construction must begin. BACT could change considerably in three years; 
accordingly, our PSD regulations (40 CFR 52.21(r)(2)) provide: 

Approval to construct shall become invalid if construction is not commenced within 
18 months after receipt of such approval, if construction is discontinued for a period 
of 18 months or more, or if construction is not completed within a reasonable time. 
The Administrator may extend the 18-month period upon a satisfactory showing that 
an extension is justified. This provision does not apply to the time period between 
construction of the approved phases of a phased construction project; each phase must 
commence construction within 18 months of the projected and approved 
commencement date. 

Response: 

See response to Comment #60. 

65. Although the Montana SIP does not appear to contain an equivalent provision, it does 
contain ARM 17.8.819, "Control Technology Review," which corresponds to our 40 
CFR 51.1660). Subsection (4) of ARM 17.8.819 provides that for phased 
construction projects, the determination of BACT must be reviewed and modified as 
appropriate "at the latest reasonable time which occurs no later than 18 months prior 
to commencement of construction of each independent phase of the project. At such 
time, the owner or operator of the applicable stationary source may be required to 
demonstrate the adequacy of any previous determination of BACT for the source." 

Chapter 4 4-22 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



This makes clear the maximum length of time a BACT determination should be 
considered valid is 18 months, and although the Roundup Project has not been labeled 
a phased construction project, we believe the permit must include a term, consistent 
with ARM 17.8.819(4), requiring review of and potential revision to BACT if 
construction does not begin within 18 months. In the alternative, the permit should be 
revised to require that construction begin within 18 months. 

Response: 

See response to Comment #60. 

66. The draft permit does not provide a method for monitoring compliance with the VOC 
emission limit in section II. A. 10. 

Response: 

State regulations do not require preconstruction permits to have monitoring 
compliance plans for all regulated air pollutants; however, the Title V operating 
permit, if issued, will address VOC methods for monitoring compliance. 

67. The draft permit does not indicate how the DEQ determined that the 10 to 12-year-old 
PM-10 ambient data represent the year preceding the receipt of the application. We 
believe the DEQ should provide an explanation as to why the data represents the year 
preceding the receipt of the application, or require that ambient PM-10 data be 
collected that represents such timeframe. 

Response: 

The Project Proponent consulted with DEQ prior to submitting the air quality 
permit application. Since there have been no significant additional sources 
constructed or operating in the Project area since the PM W data were collected, 
DEQ agreed that 12-year old PM 10 ambient data represented baseline ambient 
data and was appropriate to use as ambient pre-monitoring data. 

68. The Preliminary Determination cover letter correctly describes the total generating 
capacity of the two main boilers as "nominal 180-megawatt (MW)." However, 
several locations in the Permit and the Permit Analysis refer to each boiler simply as 
a "390-MW PC Boiler." Part l.A of the Permit Analysis refers to " Two steam 
turbine-generators rated at 390-megawatt (MMW) gross electrical output each." To 
avoid confusion and to maintain consistency, it would be best to insert the word 
"nominal" at each of these locations, or simply refer to each "main boiler." As shown 
in the spreadsheets included in Appendix B of the permit application, each of the 
main boilers is capable of generating more than 390 MW when operating in the 
"valves wide open and 5% overpressure" mode. 

Response: 

DEQ agrees with this comment and will update the final air quality permit if 
one is issued. 

69. In Section LB, the plant location is described as "just east of Old Divide Road." It 
should say "north." 



Montana DEQ 4-23 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



Response: 

DEQ agrees with this comment and will update the final air quality permit, if 
one is issued. 

70. In Section II. A, Condition 5 abbreviates "million British Thermal Units" as 
"mmBtu." However, all other parts of the Permit Analysis use "MMBtu." To avoid 
confusion, "MMBtu" should be used in Condition 5. 

Response: 

DEQ agrees with this comment and will update the final air quality permit, if 
one is issued 

71. In Section II. A, Conditions 6 through 10 provide lb/hr emission limits for the main 
boilers, but the values were calculated using 3,737 MMBtu/hr, which is the maximum 
annual average heat input. As shown in the permit application and explained in our 
response to DEQ's 2/27/02 request for additional information, each boiler will be 
capable of operating at 4,013 MMBtu/hr (in the "valves wide open and 5% 
overpressure" mode). Since the boilers probably will operate in this mode for some 
periods of time, the lb/hr emission limits should be based on 4,013 MMBtu/hr. The 
correct values are shown in bold font below. In addition, we have added tons/yr 
emission limits based on the maximum annual heat input (3,737 MMBtu/hr x 8,760 
hr/year = 32,736,120 MMBtu). ... 

Response: 

DEQ agrees that the short-term emission limits should be based upon 4013 
MMBtu/hr. DEQ will update the final air quality permit to use this value, if the 
air permit is issued. 

72. In Section II. A, Condition 16 limits the combined diesel oil consumption of the two 
auxiliary boilers to "5,438,400 gallons per rolling 12-month period." The correct 
value should be "2,719,200" gallons (based on 824 gallons/hr and 3,300 hours/year 
total for both boilers). 

Response: 

DEQ agrees with this comment and will update the final air quality permit, if 
one is issued. 

73. In Section II.B, Conditions 1, 2, and 3 require that emission testing of each main 
boiler "shall continue on an annual basis" after completion of the initial compliance 
tests. Annual emission testing is unnecessary for NOX and SO2, because these 
pollutants will be continuously monitored. In addition, we believe the standard period 
of emission testing is every 5 years. We recommend changing Conditions 1, 2, and 3 
to require emission testing every 5 years or as requested by the Department after 
successful completion of the initial compliance tests. 

Response: 

DEQ is examining the testing schedules and record keeping requirements 
contained in the draft air quality permit. DEQ's internal testing guidance and 



Chapter 4 4-24 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



the use of CEMS will affect the ultimate decision on testing frequency. DEQ's 
final decisions will be discussed in the ROD and the final air quality permit, if 
one is issued. 

74. In Section II.D, Condition 2 requires continuous emission monitoring in accordance 
with several regulations, including 40 CFRPart 60, Subpart Db. This reference is not 
correct. For the Roundup project, only the auxiliary boilers are subject to Subpart Db, 
and the auxiliary boilers are not required to have (and will not have) continuous 
emission monitors. 

Response: 

The intention of this permit condition is to identify the subparts that apply to 
units at the facility, not to impose a condition that is not already required by the 
New Source Performance Standards (NSPS). DEQ will add text to the final air 
quality permit, if one is issued, to clarify the intention of the permit condition. 

75. In Part II. C, the third and fourth paragraphs under Item 7 say that "Roundup Power is 
an affected facility" under 40 CFR 60, Subpart Da and Subpart Db. These paragraphs 
should be revised to clarify that only the main boilers are affected facilities under 
Subpart Da (which defines an "affected facility" as a steam generating unit that is 
used to generate electricity) and only the auxiliary boilers are affected facilities under 
Subpart Db (which defines an "affected facility" as a steam generating unit that is not 
subject to Subpart Da). 

Response: 

DEQ will add language to the final air quality permit, if one is issued, to clarify 
the applicability of the NSPS subparts (Subpart Da and Subpart Db) to the 
Project. 

76. In Part II. C, the fifth paragraph under Item 7 says that "Roundup Power is an affected 
facility" under 40 CFR Part 60, Subpart Y. This paragraph should be revised to 
clarify that only the coal handling equipment is an affected facility under Subpart Y. 

Response: 

DEQ will add language to the final air quality permit, if one is issued, to clarify 
the applicability of the NSPS Subpart Y to the Project. 

77. In Part II. H, Item 2. a contains a list of pollutants for which Roundup has a PTE 
greater than 100 tons/year. Carbon monoxide (CO) should be added to this list, and 
VOCs should be deleted. 

Response: 

DEQ agrees with this comment and will update the final air quality permit, if 
one is issued. 

78. In Part IV, several numerical values in the "emissions inventory" are incorrect. . . 
correct values are shown in bold font below. . . . 

Response: 



Montana DEQ 4-25 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



DEQ will review the emission inventory and update the inventory as 
appropriate for the final permit, should a final permit be issued. 

79. We appreciate MT DEQ's concern regarding collateral impacts of wet (versus dry) 
scrubbing. However, given the need to further reduce S0 2 emissions due to their 
impact upon Yellowstone NP and UL Bend WA, we believe that wet scrubbing (with 
addition of a wet ESP to control acid mist) should remain a viable option. Even if the 
dry scrubber option becomes the final determination for this project, we believe that 
dry scrubbing technology can achieve lower emission than the 0.12 lb/mmBtu rate 
proposed. 

Response: 

DEQ still believes that, upon consideration of the collateral environmental 
impacts (arid region and need for deep water wells), the appropriate BACT 
determination is the dry scrubber that was required in the preliminary 
determination. However, DEQ is still considering the ultimate BACT 
determination. DEQ's final decision will be described in the ROD. 

80. We (NPS) continue to believe that the RPP has the potential to create adverse impacts 
to visibility at Yellowstone NP and UL Bend WA, if allowed to operate under the 
conditions outlined in the Preliminary Determination on Permit Application. We 
(NPS) reiterate the need to reduce emissions from the proposed Roundup facility, in 
order to reduce or eliminate potential impacts to AQRVs at Yellowstone NP and UL 
Bend WA. 

Response: 

See responses to Comments #1 - #19. 

8 1 . Roundup failed to conduct one year of preapplication ambient monitoring. 

Response: 

Based upon the results of the ambient S0 2 monitoring conducted by the 
Proponent, DEQ determined that 4 months of monitoring was adequate to 
establish the background S0 2 concentrations in the area. However, DEQ expects 
that the Proponent will collect one year of data. Because the Proponent satisfied 
state requirements, DEQ has no authority to require the Proponent to collect 
additional ambient S0 2 data. Therefore, the permit does not contain a condition 
requiring the Proponent to collect the additional ambient S0 2 data. 
Furthermore, based on internal DEQ guidance, the Proponent is not subject to 
preconstruction permit monitoring requirements. 

DEQ accepted the PMi data collected by the mine as satisfying the pre- 
application monitoring requirements for PM 10 . 

82. Key conditions of the draft permit fail to comply with federal and state regulations. 

1. Condition II.D.l fails to require continuous inlet and outlet S0 2 monitoring 

pursuant to the requirement of 40 CFR § 60.47a(b)(l). 

Response: 



Chapter 4 4-26 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



The Project is subject to the provisions of the applicable New Source 
Performance Standards (NSPS). Because Condition II.D.l of the permit does not 
reiterate the provisions of a particular NSPS does not void the requirements of 
the particular NSPS. 

2. Condition III.H of the draft construction permit provides that construction 
must begin within three years of permit issuance. This is in direct conflict with 
ARM 17.8.73 1 of the EPA-approved SIP which states that the permit may 
contain a provision that the permit will expire unless construction is 
commenced by the date specified in the permit which in no event may be less 
than one year after the permit is issued. Thus, the permit must include a 
condition that it will expire if construction is not commenced within one year 
of issuance of the permit, and no extension for commencing construction 
should be granted without a reanalysis of best available control technology 
(BACT). 

Response: 

The rule cited in the comment does not state that the permit shall expire if 
construction has not commenced within 1 year. One year is the minimum time 
that DEQ may identify for construction to commence. DEQ does not believe that 
a 1-year time frame is appropriate in this case. 

However, DEQ is currently considering revising the preliminary determination 
to reflect that if the facility does not commence construction within 18 months of 
permit issuance, a new BACT analysis will be required before construction can 
commence. Any final decisions will be reflected in the final air quality permit, if 
one is issued. See response to Comment #60. 

3. Condition II. C. 2 of the permit is based on a state provision in ARM 
17.8.705(l)(r) that allows for "de minimis exemptions" from construction 
permitting requirements which have not yet been approved by EPA as part of 
the SIP. Thus, this provision must be deleted from the construction permit, or 
this permit will allow violations of the EPA-approved SIP. Instead, a 
provision must be added requiring any change that would increase potential 
emissions of the source to require a construction permit from the MTDEQ 
prior to commencement of construction on the change. 

Response: 

See response to Comment #61. 

4. The permit must state the maximum hourly capacity of the boilers as a 
condition of the permit, since it was relied on in determining the short-term 
emissions rates for the air quality modeling analysis. 

Response: 

DEQ does not believe that a permit condition is necessary regarding the 
maximum hourly capacity of the boilers. Furthermore, monitoring compliance 
with such a condition would be extremely difficult. DEQ believes that the other 
conditions in the permit will protect the analyses done for the permit 



Montana DEQ 4-27 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



application. However, DEQ will take this suggestion into consideration for the 
final permit application decision. 

83. The permit fails to include a practically enforceable emission limit for VOCs. 
Response: 
See response to Comment #66. 

Greenhouse Gases 

84 Carbon sequestration is a viable measure that should be seriously considered to 
mitigate the harmful GHG discharges from Roundup. 

Response: 

No existing federal or state regulations require the mitigation (e.g., carbon 
sequestration) of GHG discharges from the Project . Therefore, DEQ has no 
authority to mandate GHG mitigation. 

85. ...This plant will significantly increase Montana's contribution to the problem of 
global warming by releasing 8.2 million tons of carbon dioxide per year. Any 
increase - particularly an increase of that magnitude - is unacceptable, particularly 
when alternative sources of energy are available.... 

Response: 

See response to Comment #84 

86. Carbon dioxide did not appear to be addressed by the power plant information. 

Response: 

See response to Comment #84. Carbon dioxide was, however, discussed in the 
DEIS. Please see page 4-20 of the DEIS for the Greenhouse Gas Estimates. 

Draft EIS Issues 

87. Page 3-4, 3.2.3: Add, "The town of Lame Deer, MT, PMio non-attainment area, is 
located (down wind) southeast of RPP. 

Response: 

Comment has been noted, and the sentence will be added to that paragraph. 

88. Page 4-16, 4.2. 1 : Paragraph number 2: change the last sentence to read: "The 
closest federal non-mandatory Class I area is the Northern Cheyenne Reservation 
(NCR), located 130 (81 miles) km southeast of the site." 

Response: 

Comment has been noted and the sentence will be edited to read as the comment 
states. Also, similar language will be used in other areas in the DEIS where the 
Northern Cheyenne Indian Reservation is stated (e.g., Page 3.9, Section 3.3.2: 
Paragraph number 3). 

Chapter 4 4-28 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 

89. Table 4-6 should be corrected to state "482 lb/hr S0 2 , 24-hour basis" instead of 448.4. 
Response: 

Comment noted. Document will reflect this change 

90. Page 4-17, 1st Full paragraph. It should be explained that the 10% change calculation 
is relative to the Federal Land Manager's pristine background values for Class I areas 
in the Western United States. 

Response: 

Comment noted. Document will reflect this change 

Land Use / Socioeconomics 

91. ... proposed direction of the railroad associated with the Power Project.. . .Old 
Divide Road, on the northern most end is .9 to 1.0 mile from the road to the house, 
Cole road. Cole Road is not labeled, in spite of the fact that there is mention of 8 
residences, nearby....". Exactly how near is very cryptically avoided.. . . Simply 
enough, the project report, (draft), could easily have included the state mile markers, 
but again, this minimal information is not included. 

Response: 

Road will be labeled. 

92. On page 3-77, under Social Well-being, it is states "Roundup residents tend to favor 
new coal development, whereas the ranchers and Bull Mountain "mini-farmers" are 
perceived by Roundup residents to oppose it." Residents from the Bull Mountains 
have showed up in substantial numbers to support this proposed project at the 
Roundup Scoping Session and other public meetings related to the proposed project 
and the EIS. That perceived opposition has mostly disappeared. 

Response: 

During the public hearing on the DEIS held December 5, 2002, in Roundup, 15 
of the 17 persons giving oral testimony (ranging from legislators to private 
citizens) supported the Project. The other two persons had reservations but 
were not totally opposed to the Project. 

93 . Lack of full consideration for the Positive economic impact the proj ect would have to 
this region 

Response: 

Analysis of the Census Bureau's reports from the 1992 and 1997 Censuses of 
Government ("Local Government Finances for Individual County Areas by 
State: 1991-92 and 1996-97") show a general deterioration in fiscal health for 
the county and other local jurisdictions of Musselshell County. After converting 
account balances to constant value dollars and dividing by the respective years' 
populations, per capita levels of revenues from county sources (mainly property 
taxes) and expenditures on most public services declined in real terms. On the 
revenue side, transfers from the federal and state governments slightly offset 

Montana DEQ 4-29 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



declines in locally-generated revenues, leading to a 7.3% increase in real per 
capita total revenues between FY 1992 and FY 1997 - this despite a 16.2% 
decrease in locally-generated taxes and other revenues over the five-year period. 
Expenditures in all categories except education declined in per capita terms, 
most in double-digit percentages. Per capita educational expenditures increased 
by only 2.3%. 

The general downturn in the national economy since 1999-2000 undoubtedly has 
affected fiscal conditions in Montana and Musselshell County. Documentation of 
the extent of the impact from the U.S. Census Bureau will not be available until 
the 2002 Census of Governments has been compiled and published. But it is safe 
to say that the ability of local governments to meet demands for services has 
been severely constrained by limitations on local revenue sources. The lack of a 
strong economic base in Musselshell County is the primary factor, which would 
be significantly alleviated by the construction and operation of the Project and 
Bull Mountain Mine. 

94. Once tax revenues increase, we can deal with these issues appropriately. When you 
couple the impact of the mine construction and power plant construction, we will 
have some significant impact quickly and these will be before new revenues begin. 
Since paragraph 4.12.1 rightfully acknowledges the perspective of both projects, the 
rest of the document should do so also. 

Response: 

This is a cash flow issue. Under state law (15-24-3005, MCA), local 
governmental units and school districts have the authority to impose an in-lieu- 
of-tax impact fee on new electrical generation projects located within their 
jurisdictions to compensate for the 10-year exemption from property taxes 
granted to qualifying facilities as of May 2001 (15-24-3001 and -3002, MCA). 
Affected local jurisdictions can share a fee not exceeding 0.75% of the Project's 
construction cost during the first two years of construction, rising to 1.0% 
(maximum) in the subsequent four years, and then declining to no more than 
0.8% over the final four years. On that basis, the projected $440 million cost of 
the Project would yield a maximum of $38.5 million in impact fees over the first 
10 years of the Project (after which local property taxes would become 
applicable). Refer to Table 4-1, below. 

Table 4-1 Local Electrical Generation Facility Impact Fee for Local 
Governmental Units and School Districts 

Year Imr 

~l 

2 
3 
4 
5 
6 



Chapter 4 4-30 Montana DEQ 







Annual Impact Fee 


Fee Basis 


(%) 


($ million) 


0.75% 




$3,300 


0.75% 




$3,300 


1.00% 




$4,400 


1.00% 




$4,400 


1.00% 




$4,400 


1.00% 




$4,400 



Roundup Power Project Final Environmental Impact Statement 



Annual Impact Fee 
Year Impact Fee Basis (%) ($ million) 

1 0.80% $3,520 

8 0.80% $3,520 

9 0.80% $3,520 

10 0.80% $3,520 
Total Fee (maximum) $38,280 

Total Projected Construction Cost ($ 440 million) 
Source: Montana Code Annotated Sec. 15-24-3001, et seq. 

These revenues would help to mitigate the additional costs of local public 
services arising from constructing and operating the power plant over the first 
10 years. 

95. Page 3-75, section on health and safety. The sections on law enforcement and fire 
were not coordinated with the proper department officials, . . . 

Response: 

The following contacts were made with Musselshell County authorities Rosalie 
Mercardo, dispatcher; Mark Shoup, Highway Patrol; and Chuck Poulos 
commissary manager; personal communication, January 22, 2002. Gary 
Thomas, City Hall; personal communication, January 22, 2002. Ron Solberg, 
Director of Ambulance Services; personal communication, January 22, 2002. 

96. This affects the conclusions in section 4. 12.8 because of incomplete information. The 
County Sheriff, and County Fire Chief who chairs the County Fire Council, were not 
consulted. 

Response: 

See response #95. 

97. Paragraph 4.1.1, page 4-1 discusses mitigation that may be required and mitigation 
that may be recommended as a condition for permitting. The draft EIS does not make 
any recommendations for any matter related to emergency services, nor does it 
discuss who or how these services are to be provided. The assumption seems to be 
that the county can absorb these impacts. They are not negligible during the 
construction phase due to lack of funding, and they will be significant to law, fire, 
ambulance, and roads. If mitigation of these cannot be required, they must be 
stridently sought by us. 

Response: 

Plant constructors and operators would be responsible for providing standard 
on-site fire protection and first aid for worker injuries. This Project would 
during construction however, increase the need for emergency services due to an 
increase in personnel and traffic on site. Because these services are paid for 
through local taxes, mitigation would not be required. 



Montana DEQ 4-3 1 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



98. Paragraph 4.12.6, page 4-9 1 . There is no mention of impacts to county and local 
roads during the construction phases of the mine or power plants. 

Response: 

Average daily traffic volumes on U.S. Route 87 in the vicinity of Old Divide 
Road are moderate. According to the Montana Department of Transportation, 
ADT levels between the Yellowstone County line and the town of Klein averaged 
2,322 vehicles per day in 1999 (latest data available), dropping to 1,627 VPD 
north of Roundup. East-west traffic levels on U.S. Route 12 averaged 509 VPD 
east of Roundup and 2,930 VPD west of town. No data were available for 
county-maintained roads, but levels on Old Divide Road are believed to be low, 
since it mainly serves rural residents. Construction traffic for the Project and 
Bull Mountain Mine would add to traffic levels in the vicinity of the Project, but 
in view of the close proximity of the Projects to where Old Divide Road joins 
U.S. Route 87, it is unlikely that local residents would be much affected by 
Project-related traffic. Traffic management measures like lane striping and 
shoulder widening would probably suffice. 

99. Paragraph 4.12.8, page 4-93. Musselshell County has had and continues to have a 
high crime rate associated with our poor economic conditions. The data used to 
suggest a low crime rate for 1999 was a known aberration due to faulty reporting. A 
short time prior to 1999 we had the highest crime in the state, and using 1999 data 
misrepresents our current crime statistics. 

Response: 

Crime rates can be correlated to poverty. Because the Project is expected to 
increase employment and provide a specific economic boost, however, the crime 
rate more likely would be reduced. Because the Project would increase the 
population in the county, this could place additional requirements on emergency 
services and law enforcement; however the improved economic conditions 
resulting from the new payrolls and Project procurement spending should 
significantly improve local economic conditions, which should help reduce 
crimes. 

Plant constructors and operators would be responsible for providing standard 
on-site fire protection and first aid for worker injuries. This Project would 
during construction however, increase the need for emergency services due to an 
increase in personnel and traffic on site. Because these services are paid for 
through local taxes, mitigation would not be required. 

100. The consultation section does not list any consultation with local officials. Nowhere 
in the document was Disaster and Emergency Services referenced or consulted. 

Response: 

See response to Comment #96. 

101 . In the reference section, land use portion, county subdivisions and planning is the 
source for the facts-at-a-glance document. 

Response: 



Chapter 4 4-32 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



Comment noted. Reference section will reflect the following source of the facts- 
at-a-glance document, Musselshell County, Montana County Subdivisions and 
Planning. 

102. The meaning or intent of the third sentence in the first paragraph on page 3-74 that 
begins "The Montana Department of Transportation does not attempt to justify. . ." is 
not clear. A better explanation of what is intended should be provided or the sentence 
deleted. 

Response: 

Sentence will be removed. 

103. In the second paragraph on page 3-74 US Route 87 and US Route 12 are referred to 
as SR 87 and SR 12. If this SR is identifying the roadways as "State Routes" it is 
incorrect. They are both US Routes. 

Response: 

Comment noted. Document will reflect these changes. 

104. Section 4. 12.4 is confusing. While the property tax amount, $26.4 million seems 
correct, the tax is over a larger base than $440 million. It should also be pointed out 
that in previous discussions with Musselshell County, a number of services not 
currently in place will need to be either created or procured (i.e. fire/emergency 
services, road improvements, etc.). The Project has discussed these with the County 
and has offered to advance pay some tax payments if these funds are used for the 
above purposes. 

Response: 

DEQ concurs with this comment. The Project Proponent has agreed to advance 
pay some tax payments. This will help alleviate the cash flow issues addressed in 
comments 93 and 94. 

Groundwater 

105. What if my well drains into this so-called Madison aquifer, and when the mining 
operations use thousands of gallons of that water, my water is lost to the deeper level? 
Will I be faced with "proving I had water before the mine opened, or proving it is the 
mine's fault that my source is gone?" 

Response: 

Local users probably obtain water from wells screened in the Fort Union 
Formation. The Project will obtain water from the Madison Formation. Based 
on the hydrogeologic properties of the strata between the Fort Union Formation 
and the Madison Aquifer, which is approximately 7,900 feet deep at the site, it is 
unlikely that the two aquifers are connected. These two aquifer systems are 
separated by thousands of feet of silt and clay that act as confining layers. These 
confining layers inhibit the movement of water between the aquifers. In 
addition, available data indicate a strong upward vertical gradient in the 
Madison Aquifer. The vertical gradient in the Madison Aquifer causes water 

Montana DEQ 4-33 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



levels in wells drilled into this limestone formation to rise thousands of feet 
above the upper contact of the formation at 7,900 feet below the ground surface. 
The proposed pumping rates for water used by the mine from the Madison 
Aquifer should not affect the upward vertical gradient. The combination of a 
strong upward vertical gradient and confining layers separating the aquifers 
make it virtually impossible for the water resource in the Fort Union Formation 
to be lost to the Madison Aquifer. 

106. Potential impacts to residents in the area from withdrawal of water from Madison 
formation would be virtually non-existent with a properly constructed well casing 
program. Casing, cemented back to surface, set through reasonably accessible ground 
water zones would protect the various aquifers in the Tongue River member of the 
Fort Union Formation from contamination, either from Madison Formation water due 
to artesian flow or contamination due to communication from other water sands or 
coal seams. Additional casing would be run to approximate total well depth and 
cemented, not necessarily to surface, to protect not only the well bore, but also to 
prevent mixing of other aquifers. Generally, this is standard practice in wells such as 
these. 

Response: 

Thank you for your comment. 

Merchant Plant 

107. . . . This permit should be denied on other grounds as well. Being classified a 
"merchant plant" by the state will make it exempt from regulation by the Public 
Services Commission, which assures that all the power will be sent out of state, rather 
than servicing the needs of Montanans. . . . 

Response: 

The Project Proponent has stated that the proposed Project is not a merchant 
power plant. The Project Proponent intends to market shares of ownership of 
the Project to utilities that will want to own its electrical output. The owners of 
the Project will determine where they market the power, and the owners and the 
market economy will determine the price for the power. Nothing more specific is 
available, and to make more specific statements would be speculative. 

Cultural 

108. p. 1-7 It is at this point incorrect to state that the SFLPO is reviewing the project under 
section 106 of the NFLPA as no responsible federal agency is identified. SFIPO 
normally consults with DEQ or other state agencies under the Montana Antiquities 
Act and/or MEPA. 

Response: 

In Table 1-1, under Permit/Approval, the Montana State Historic Preservation 
Office provides consultation; there is no permit. Also, under Authority, the 



Chapter 4 4-34 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



reference to the National Historic Preservation Act should be changed to the 
Montana Antiquities Act; Montana Environmental Policy Act. 

109. p. 2-40 Again reference to section 106 of the NHPA is misleading unless this 
becomes a federal undertaking. We agree with generic mitigation of impacts to 
cultural resources as proposed under CR-1, -2, -3 and -4 (however we find the 
reference to section 106 technically misleading). 

Response: 

Under CR-2, "in accordance with Section 106 of the NHPA" will be deleted. 

110. p. 4-52 Again, since we have not seen the cultural resource reports we are unable to 
comment other than to agree that areas not inventoried (i.e., groundwater 
well/pipeline, disposal haul road and conveyor routes) may contain important 
unknown cultural resources. 

Response: 

Various consultants performed the cultural resource inventories used for 
describing the affected environment. All reports referenced in the Draft EIS and 
inventory forms for all known cultural resources are in the files of the Montana 
SHPO. No additional systematic surveys and no additional site recording were 
performed in preparing the Draft EIS. 

111. Whether or not we are requested to provide comment on specific site significance, 
effects or mitigation we believe it would be appropriate that the cultural resource 
reports prepared for this project be submitted to our office for inclusion in the 
statewide inventory; see M.C.A.22-3-423. 

Response: 

See response #110 

Purpose & Need 

1 12. The report states on Page 2-21, that "the potential purchasers of electricity generated 
by the Project are power distributors (i.e., utilities) and commercial owners in 
Montana and the western United States." By adding an explanation of the loads 
anticipated to be served along with the energy & capacity to be supplied to each will 
not only make the purpose and need more clear but will also aid the reader in 
understanding the need for and financial feasibility of the transmission line, which is 
also unclear. 

Response: 

The Project owners are in the north portion of the Western Electricity 
Coordinating Council. Each is an equity owner of their share as a base load 
component of their generation supply mix. Each has identified their generation 
needs for 2006 and beyond and the Project is intended to be an integral part of 
their supply portfolio. 



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Final Environmental Impact Statement Roundup Power Project 



Their generation needs are the result of a combination of load growth and 
cancellation or reduction of existing contracts. Each may also have other 
generation projects to make up the remaining portion of their supply portfolio. 
However, the Project is a low cost project and is intended to provide a reliable 
base load component to each of the owners. 

Data from the Pacific Northwest Utilities Conference Committee's (PNUCC) 
regional forecast in November 2002 show a regional shortfall of just over 4000 
MW in 2005-6 and 4738 MW in 2006-7. The Project is intended to serve some of 
the utilities represented in this study. A similar situation exists for all other 
utilities in the north portion of the Western Electricity Coordinating Council. 
The PNUCC has 55 public and private utility and direct served industry 
members. 

The Bonneville Power Administration has notified numerous utilities and direct 
served industrial customers of cancellations or reductions in existing contracts. 
Bonneville Power Administration has also notified customers that it will expect 
utilities to make their own arrangements for load growth rather than Bonneville 
Power Administration buying power on the market or arranging for power 
contracts to serve those utilities. 

113. The Roundup Power Plant will produce energy that the state of Montana does not in 
fact demand. In establishing the need for the plant, MDEQ makes no mention of 
Montana-specific supply and demand statistics. By comparison, the Energy 
Subcommittee of the interim legislative Environmental Quality Council recently 
released its report, "Understanding Electricity in Montana" (December 2002) that 
documents the actual power generation supply and demand data in Montana. 
According to the data tables contained in that report (and prepared by MDEQ), it 
appears that Montana has little, if any, need for additional power generation. Table E6 
indicates that in the year 2000, Montana consumed a total of 14,569 million kilowatt 
hours of electricity, which is equivalent to 1663 aMW. Table E2 indicates that 
Montana produces, on average, 3,177 aMW. In other words, Montana already 
produces nearly twice as much electricity as it consumes. While it is true that much of 
that power is owned by out-of-state utilities and the federal government, it is also true 
that many Montana utilities have significant access to (and contracts for) federal 
power at extremely competitive preference rates. In the absence of the formal "needs 
analysis" formerly required by the Major Facility Siting Act, MDEQ lacks a reasoned 
basis for asserting a need for this facility — especially a state or local need. 

Response: 

DEQ agrees that there may not be a need for the Project. The owners of the 
Project have indicated that they can market much of the output of the Project 
within Montana, that the cost of the power will be competitive, and that 
transmission would be available in the future to sell additional capacity to out- 
of-state customers. It will be up to the ultimate owners of the Project to use the 
Project's capacity within their service territory or sell some of that capacity into 
the open marketplace. The provisions of the DEIS that discuss the need for the 
Project should have been stated in terms of the potential benefits of the Project. 
Those provisions have been stricken and replaced in the FEIS. While the Project 
may provide needed generation for in-state and out of-state consumers, and may 



Chapter 4 4-36 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



result in more competition and lower prices, the owners of the Project would 
determine where they market the power, and the owners and the market 
economy will determine the price for that power. 

1 14. Even if Montana's load did increase 260 MW, recently permitted facilities such as 
Northwestern (150 MW), Hardin (113 MW), Basin Creek (96 MW), and Thompson 
River Cogen (13 MW) could easily meet any such need. 

Response: 

This may be correct. However, it cannot be assumed that any particular plant, 
especially a recently permitted plant, will be on line at any given time. Across 
the country permitted projects have been put on hold or cancelled. 

115. The DEIS suggests that there are continuing, new electrical generation needs in light 
of the retirement of aging units. But if the power from this facility is in fact meant to 
serve as replacement power from existing Montana generators, the Final EIS should 
include a decommissioning timeline for those facilities. 

Response: 

DEQ agrees that any timeline for decommissioning of aging power generation 
facilities is speculative. The DEIS should have stated that power generated by 
the Project could help meet any increased demand resulting from any 
retirement of older generating units that may occur in the future. 

116. To the extent that this facility is meant to serve a regional or national need as opposed 
to a Montana need, MDEQ should address the results of recent 2002 studies by 
RAND and by the Tellus Institute. The Tellus report projected an increase in regional 
demand of 5,830 aMW (from 21,345 aMW in the year 2000 to 27,742 aMW in 2020). 
The report concluded that the region could meet all of this new demand (as well as 
some replacement power) with a combination of cost-effective conservation (3,542 
aMW) and new, cost-competitive wind, biomass, and geothermal resources (9,954 
aMW). These resources have no direct emissions of air pollutants, and provide the 
benchmark for comparison when speaking of "clean" resources. The transition to a 
clean energy future does not, and cannot imply the use of traditional coal -based 
power generation. MDEQ's characterization of the Roundup power plant as "clean" 
generation simply cannot be taken seriously. 

Response: 

DEQ agrees that conservation and alternative energy sources could meet some 
or all of the projected increase in power demand and would provide air quality 
benefits compared to a new efficient coal-fired plant. However, Project would 
meet the requirements of the Clean Air Act, and would utilize state of the art 
emission reduction technology. 

117. We are also concerned that MDEQ unreasonably overestimates demand growth in 
justifying this facility. Load growth projections contained in section 1.3 of the DEIS 
seem wildly over-exaggerated. That we would see a 30% increase in demand (from 
120,000 MW in 2001 to 165,000 MW in 2010) does not comport with either 
historical trends or other forecasting sources. For example, the Northwest Power 



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Final Environmental Impact Statement Roundup Power Project 



Planning Council's "Medium Case Consumption Forecast" estimates a 13.7% increase 
over a similar period - from 20,442 aMW in 2000 to 23,234 aMW in 2010. DEQ 
should also take into consideration the large, already-permitted fleet of power plants 
that came as a response to the 2000-2001 power crisis. Predictions of future supply 
shortages, when they are made, are not based on an absence of permitted power 
plants, but rather on the financing and other economic challenges these plants face. 

Response: 

DEQ disagrees that the sources cited in the DEIS are not legitimate. The 
historical peak demand for the 2001 calendar year was 125,000 MW. The data 
sited encompasses the entire Western Electricity Coordinating Council 
(WECC). This data reflects the coordinated plans of the WECC organization as 
of January 1, 2002. DEQ does agree that the Project faces other challenges if the 
Project is permitted, including financing and economics. 



Ash/Waste 

118. The proponents of RPP have proposed an interesting fly ash disposal solution. DEQ is 
correct in preferring the plant site storage alternative. However, what happens when 
the 30 years are up? The life of the plant is estimated at 40 years on page 4.20. That 
would indicate a need for fly ash disposal for at least 40 years. 

Response: 

The fly ash storage facility plan specifies design of on-site storage for 10 years 
capacity in two cells. The preferred alternative specifies design of additional 
cells for placement of fly ash waste for the anticipated life of the plant, an 
additional 30 years. 

119. Does DEQ have the authority to make RPP accept DEQ's preferred alternative for 
waste disposal? If so, under what law or regulation? 

Response: 

DEQ prefers this alternative because DEQ believes that it would cause less 
environmental impact; however, DEQ does not have the authority to require the 
Project Proponent to accept alternative waste disposal. The Project Proponent 
would have to voluntarily implement that option. 

Visual Impacts 

120. On page 4-60, the report indicates that the visual impacts of the two 574-foot Project 
chimneys and the 250-foot high boiler buildings which sit on top of a major drainage 
divide are 'moderate'. I believe that the impacts are going to be much more severe 
than 'moderate', e.g., the infrastructure, strobes and hot exhaust gases will stick out of 
the landscape like Rudolph's nose and will destroy much of what tourists come here 
for. 



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Roundup Power Project Final Environmental Impact Statement 



Response: 

The proposed Generation Plant is sited atop a drainage divide for two 
intermittent creeks (Rehder and Halfbreed Creeks) in the area (see section 3.3, 
Water Resources in DEIS). Rolling hills, foothills and mountains surround the 
proposed Generation Plant site. Refer to figure 2-1 to see the neighboring Bull 
Mountain buttes that surround the proposed Generation Plant site. Clear, 
unobstructed views of the Project facilities would be limited only to the local 
area as discussed on pages 3-43 and 4-60 of the DEIS. 

The visual impacts were considered moderate overall because views of the 
Project would occur to some degree in the middle ground distance zone, while 
most Project views would occur in background distance zone. Refer to tables 4- 
23 and 4-24 in the DEIS for the impact assessment process followed by a 
discussion thereafter on impact levels. 

Scenic views that attract tourists occur approximately 116 miles to the southwest 
at Yellowstone National Park. Scenic highways generally do not occur in the 
Project study area and therefore the number of tourists focused on scenic views 
in or near the Project study area would be expected to be low. Recreational near 
the proposed Generation Plant site includes dispersed outdoor activities such as 
hunting and horseback riding (see page 3-57 of DEIS). These activities are not 
generally dependant upon pristine landscapes or areas of high scenic quality. In 
addition, for these recreational pursuits to occur, landowner permission must 
first occur, as most land near the Proposed Generation plant is privately owned. 
The nearest public recreation facilities (including a golf course, tennis courts, 
and swimming pool) are within the City of Roundup, more than 13 miles from 
the proposed Generation Plant, (see pages 3-57 and 3-58 of the DEIS). 

121 . From the top of Dunn Mountains are visible the Little Wolf Mountains, the Wolf 

Mountains, the Big Horn Mountains, The Pryor Mountains, the Beartooth Mountains, 
the Crazy Mountains, and the Snowy Mountains. I suspect that if RPP operates, we 
will say goodbye to the Wolfs and the Little Wolfs, It is a lovely view. 

Response: 

There is no conclusive evidence to suggest that the view would be lost. The top of 
the proposed Generation Plant chimneys would not obstruct any views from 
Dunn Mountain. The Little Wolf Mountains and the Wolf Mountains would 
both remain visible from Dunn Mountain if the Project were constructed. The 
top of the Project's chimneys would occur approximately 181 feet below the 
elevation found at the top of Dunn Mountain. The Project would also be located 
approximately 4.25 miles away from Dunn Mountain. Any viewpoints located on 
Dunn Mountain are not developed and do not contain residences, public roads, 
or parks. Any views of the Project from Dunn Mountain would occur from 
dispersed recreationists while on horseback or hunting, refer to section 3.11, 
Land Use in the DEIS. 

Atmospheric haze that may occur as a result of the Project that would be seen 
from viewpoints nearby (Dunn Mountain) would not occur any higher than 
opacity limits set forth in the air quality permit. Since there were no Class I PSD 
areas or integral vistas within 50 km per Montana State regulations, a plume 
blight analysis was not performed nor statutorily required, refer to section 3.2, 
Air Resources in the DEIS. 

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Final Environmental Impact Statement Roundup Power Project 



Vegetation 

122. Statements on Pp. 4-39 (see 4.5.2) concerning p. pine are incomplete. 
Response: 

This is covered on page 4-19 & 20; Section 4.22. 

Fish & Wildlife 

123. "The states, territories, and Native American tribes have primary responsibility for 
protecting residents from the health risks of eating Mercury contaminated fish and 
wildlife." 

Response: 

There is no conclusive evidence that the Project would have mercury emissions 
with serious, adverse impacts on public health and the environment. Mercury 
deposition has always occurred naturally within the regions streams, lakes, 
rivers and the human body is able to adapt to the mercury found in the natural 
environment. Much of the mercury in Northwestern fish originates from natural 
deposits in rocks and soils, with some influence from historic mining practices 
(Oregon's Fish Advisories for Methylmercury). 

Mercury releases from power plants may influence the amount of 
methylmercury in freshwater fish living in some U.S. lakes and streams. Health 
risks from power plants depend largely on how much those plants influence the 
amount of methylmercury in fish that people eat. In several case studies 
sponsored by EPRI, independent researchers found that the amount of 
methylmercury in lake fish that might come from nearby power plants was well 
below the amount that EPA says people may take into their bodies without 
harming their health (Colorado Mining Association, Health Risk Profiles- 
Mercury). At freshwater lakes and rivers known to be contaminated with 
mercury, many states post "fish advisories" telling fishermen how many and 
which kinds of fish their families can safely eat. 

Role of the Project Proponent in Preparing the DEIS 

124. Finally, as a general comment, we strongly object to the State allowing the company 
to write major portions of its own environmental review. The language found in 
Section 1.3.1, for example, is taken nearly verbatim from the language submitted by 
the company in its "EIS Support Document" submitted in May of 2002. 

Response: 

Your comment is noted. DEQ can use any legitimate source of information that 
might be available when preparing an EIS. This information often includes that 
provided by the Proponent, especially information contained in the permit 
application. 



Chapter 4 4-40 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



Montana Constitution 

125. The Roundup Power Project does not comply with the Montana state constitution. We 
believe similar issues are raised with the permitting of this facility, which poses even 
greater adverse environmental impacts than earlier proposals. To address this core 
legal responsibility, MDEQ must explain whether the justification quoted above is 
meant to satisfy the "compelling state interest" test. If so, we respectfully request 
specific information as to what formula the Department has devised to determine an 
acceptable tradeoff between environmental degradation and economic benefit. 

Response: 

District Court Judge Jeffrey Sherlock recently rejected the argument of the 
Montana Environmental Information Center (MEIC) that DEQ was required to 
deny an air quality permit for another proposed power plant based upon the 
Constitutional right to a clean and healthful environment, even though the plant 
would comply with applicable air quality statutes and rules. Judge Sherlock 
ruled that DEQ is required to faithfully execute the air quality statutes and rules 
of Montana, unless it has been demonstrated that those laws are 
unconstitutional. MEIC has not demonstrated this. 

Article IX, Section 1(2), of the Montana Constitution, provides that the Montana 
Legislature shall provide for the administration and enforcement of the duty of 
the state and each person to maintain and improve a clean and healthful 
environment. Article IX, Section 1(3) further provides that the Legislature shall 
provide adequate remedies for the protection of the environment. The Montana 
Legislature has provided for protection of the state's environment through acts 
such as the Clean Air Act of Montana. Under Montana law, acts of the 
Legislature are presumed to be constitutional, and a person challenging the 
constitutionality of a legislative act has the burden of proving beyond a 
reasonable doubt that the act is unconstitutional. Unless determined in court to 
be unconstitutional, DEQ must presume that the Clean Air Act meets 
constitutional requirements and must implement that act in response to an 
application for an air quality permit. If DEQ determines that the application for 
an air quality permit for the Project demonstrates that the Project can be 
expected to meet the air quality standards adopted by administrative rule under 
the Clean Air Act, the Montana Constitution does not provide a legal basis for 
DEQ to base its decision on the permit, instead, upon the suggested balancing of 
environmental degradation and economic benefit. 

The Clean Air Act does not provide DEQ with authority to deny an air quality 
permit when the proposed Project can be expected to comply with air quality 
requirements. Further, Section 75-l-201(5)(a), MCA, of the Montana 
Environmental Policy Act (MEPA), expressly prohibits DEQ denying or 
conditioning a permit based upon DEQ's review of the application under 
MEPA. Consideration of environmental impacts beyond review for compliance 
with applicable requirements and consideration of the economic benefits of a 
proposed Project are MEPA considerations that, by law, DEQ may not rely 
upon in making its decision on the permit application. 



Montana DEQ 4-41 Chapter 4 



Final Environmental Impact Statement Roundup Power Project 



126. That MDEQ is unable to require mitigation to "avoid, reduce, or eliminate potential 
impacts" makes the consideration of Montana's Constitutional duty "to maintain and 
improve a clean and healthful environment" even more relevant. If the Department 
cannot require sufficient mitigation of impacts including, but not limited to, those 
identified in the DEIS to fulfill this Constitutional duty, than it must instead select the 
No- Action alternative. 

Response: 

DEQ has authority to require mitigation measures necessary to ensure 
compliance with the air quality standards adopted under the Clean Air Act of 
Montana. These measures become enforceable conditions of any air quality 
permit that is issued. As discussed above in the response to Comment No. 125, 
DEQ is prohibited by law from imposing requirements beyond those needed to 
comply with the standards adopted under the Clean Air Act. Impacts unrelated 
to compliance with air quality requirements do not provide legal authority to 
select the "no action" alternative. 

Alternative Fuel 

127. For the purposes of this document, the Final EIS should at a minimum acknowledge 
the risk associated with the proposed design in light of future environmental 
regulation. The EIS should also note the drawback of a proposal that would decrease 
the diversity of Montana's energy mix. 

Response: 

The Project would meet the requirements of the Clean Air Act and all relevant, 
applicable and appropriate requirements. Several energy alternatives were 
evaluated and the Proposed Action was determined to provide a balance of a 
solid, reliable, and economically feasible energy source for Montana. 

128. The DEIS must also thoroughly evaluate the use of lower sulfur coal including coal 
blending to satisfy BACT and MEPA requirements. 

Response: 

The DEIS considered and dismissed further evaluation of other coal and other 
fuel sources. DEQ believes that the analysis is adequate. Refer to page 2-42, 
Section 2.3.1, of the DEIS. All conditions are satisfied. 

Alternative Technologies 

129. Integrated Gasification Combined Cycle's (IGCC) Environmental Performance is 
Superior to other Technologies for Generating Electricity from Coal. 

Response: 

Comments were adequately addressed on page 2-45 Section 2.3.4. 

130. IGCC is Economically Competitive with other Technologies for Generating 
Electricity from Coal. 

Chapter 4 4-42 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 

Response: 

See Response #129. 

131. IGCC is Not Redefining the Source. 

Response: 

It is redefining the facility and is out of scope both for an in-depth BACT and 
EIS analysis. 

132. MDEQ Failed to Consider Cost-effective Energy Efficiency and Renewable Energy 
Alternatives. 

Response: 

The DEIS identified reasonable alternatives to key elements of the Proposed 
Action, as well as a wide range of other alternatives. DEQ believes the DEIS 
adequately identified, treated, evaluated, and compared alternatives. 

Alternatives / Mitigation 

133. The DEIS fails to examine all viable alternatives and mitigation strategies. 

Response: 

The DEIS identified reasonable alternatives to key elements of the Proposed 
Action, as well as a wide range of other alternatives. DEQ believes the DEIS 
adequately identified, treated, evaluated, and compared alternatives. DEQ 
believes that reasonable mitigation strategies were identified, and is limited by 
Montana statute from imposing mitigation other than is required under permits 
issued by the State of Montana. 

Alternative Voltages 

134. The proposed alternative for transmission is flawed. The use of a 161 kV transmission 
lines to transmit 750 MW simply does not conform to best engineering practices. 

Response: 

Both the 161kV and 230kV transmission systems were shown to accommodate 
the transmission of 750MW of power. Environmental impacts would be very 
similar with either system. 

135. Throughout the DEIS, MDEQ refers to major improvements that are planned to the 
BPA transmission system (including both "substation upgrades and transmission line 
additions between Montana and the Pacific Northwest"). Pages ES-4 and 2-21 
describe plans to upgrade the transmission systems to allow an additional 500 MW to 
flow west toward the Garrison Substation, and an additional 200 MW to flow south 
toward PacifiCorp's Yellowtail Substation. Yet much more information is needed to 
completely understand such developments. 

Response: 



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Final Environmental Impact Statement Roundup Power Project 



DEQ agrees that additional work may be required on the transmission system to 
accommodate the capacity requirements of the Project. However, at this time 
there is not enough known about how much capacity would be required on any 
particular transmission system because DEQ is not aware that there are any 
contracts in place for power transactions. 

136. To ensure a meaningful public process, MDEQ must provide more specific 
information regarding these proposals, and documentation as to where additional 
information can be found. There are a number of critical questions that are not 
addressed. In particular, when will the additional transmission capacity be available? 
Who will pay for it? What guarantee is there that Roundup will acquire contract 
rights to that additional capacity (with other already-permitted proposals ahead in the 
queue)? Will these upgrades alone be sufficient to allow for the transmission of 
power to major out-of-state load centers to the west and the south (or are additional 
upgrades needed to actually move the power out-of-state)? 

Response: 

DEQ is not aware of a specific date that the transmission capacity would become 
available. The specific transmission paths needed would depend on the contracts 
that the Project Proponent would be able to negotiate with potential purchasers 
of power. This is dependent on the Project being approved and cannot be 
predetermined. Transmission line improvements would be paid for by those 
parties benefiting from any specific improvements that may be required. If the 
Project Proponent or its contract partners are capable of paying for the 
improvements, this would be implied as the guarantee of transmission access 
regardless of the queue. Since there is no way to predict the transmission 
improvements that might be required until the contracts are signed, and again, 
this would be pursued by the owner if the Project is approved. 

Eminent Domain 

137. "Eminent domain seizures could be at risk of court challenges if a landowner were to 
convince the court the public purposes of the line were speculative." 

Response: 

Transmission owners, who would have the right of eminent domain, would 
likely provide transmission access. 

Miscellaneous Issues 

138. Please note our concerns about the Bull Mountain Power Plant and mine. The effect 
on the fragile environment previously impaired by the loss of forest in a 1984 fire and 
years of drought would seem risky to us. Health issues relating to emissions are 
extremely important to us. 

Response: 

In both cases (the mine and the power plant), DEQ required that the applicant 
conduct analyses to make sure that the air emissions from the proposed sources 



Chapter 4 4-44 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



would not cause or contribute to concentrations of criteria pollutants that would 
exceed the NAAQS or the MAAQS. These standards were established at levels 
that are protective of human health and the environment. The governing rules 
and regulations for permitting sources of air emissions require that the source 
conduct certain analyses. Based upon the results of the analyses, DEQ 
determines whether the proposed source would comply with the governing rules, 
regulations, and standards. 

139. MTDEQ's Permit Proceeding Violates Core PSD Requirements by Precluding 
Meaningful Public Participation 

Response: 

The public comment period for the Project was not severely limited. In fact, the 
opportunity for public comment for the Project initial permit application was 
quite long. The Proponent submitted the air quality permit application in 
January of 2002. The public could begin reviewing and commenting on the 
permit application starting at the date of the submittal. After DEQ's review of 
that permit application and subsequent deficiency notices and responses, DEQ 
issued a preliminary determination on August 12, 2002. DEQ initially requested 
that the comments on the PD be submitted by August 27, 2002. The PD was also 
attached to the DEIS. Comments on the DEIS were due by December 18, 2002. 
Based upon these dates, the public had approximately 8 months to comment on 
the permit application prior to issuance of the PD and approximately 4 months 
to comment on the PD. 

140. MTDEQ Has Failed to Comply With the Public Review Procedures of the EPA- 
Approved SIP 

Response: 

The PD for a permit can be issued prior to issuance of a DEIS. In fact, such an 
approach actually allows the public more time to review the document than if 
DEQ were to withhold the PD until issuance of the DEIS. 

141 . Why is this EIS not being done by an appropriate Federal agency under NEPA 
instead of the Montana DEQ? 

Response: 

No federal agency has jurisdiction, and no federal permits are needed. DEQ is 
the sole permitting authority, so the EIS was prepared pursuant to MEPA. 

142. On the Roundup Power Project DEIS is in Section 2.4.2, 230kV Transmission System 
Alternative, page 2-53, second paragraph. The last sentence states, "Studies 
performed by both transmission providers have identified upgrades that are proposed 
and underway to support this flow." I suggest the following alternative. "Studies will 
be performed by both transmission providers to identify necessary upgrades to 
support this flow." 

Response: 

Comment noted. The document will reflect this change. 



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Final Environmental Impact Statement Roundup Power Project 



143. In the section titled Infrastructure Development, Transmission, Page 4-98, second 
paragraph. This paragraph states, "According to BPA, major transmission 
improvements to the BPA system are planned. These improvements would include 
substation upgrades and transmission line additions between Montana and the Pacific 
Northwest." I suggest the following alternative. "BPAT has a current project to 
increase the West-of-Hatwai cutplane capacity in Washington. However, this does not 
provide increased capacity from Montana to the Northwest. In order to provide 
service to the Roundup Power Project major facility additions will be required. This 
could potentially include substation upgrades and/or transmission line additions. 
Studies will be done in queue order based on BPAT's long-term transmission request 
queue to determine the improvements needed." 

Response: 

Comment noted. The document will reflect this change. 



Chapter 4 4-46 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 

CHAPTER 5 
MODIFICATIONS AND CORRECTIONS 

TO THE DEIS 

Page ES-1, Change heading "Purpose and Need for the Action" to "Benefits of the Action." 

Page ES-1, replace the last paragraph beginning "The primary needs for the Project. . ." with 
the following paragraph: 

The primary purposes of the Project are to serve population growth and load growth 
and provide new base load electrical generation. Population and electrical demand 
growth, together with the retirement of older, less efficient electrical generating units, 
has created a demand for new and cleaner generation sources. The Project would fill 
a portion of this demand. 

Page ES-2, replace the 1 st paragraph beginning "The Project would be built specifically ..." 
with the following paragraph: 

The Project would be built specifically to burn coal. The mine-mouth fuel source of 
the Project is intended to provide stable pricing and reliability for base load power 
assisting utilities in more reliably serving industrial, commercial, and residential 
customers. 

Page ES-2, replace the 2 nd paragraph beginning "The Project would also increase ..." with 
the following paragraph: 

The Project would increase the opportunity for competition in the regional energy 
market by increasing the total amount of electricity that could be transmitted reliably 
within the grid. Competition in the power marketplace is a means in a market 
economy to keep power pricing in line with customer demand. According to the 
Proponent, some of the electricity could be consumed by industrial, commercial, and 
residential customers in Montana. North Western Energy currently is evaluating the 
interconnection of the Project with their transmission system at the Broadview 
Substation. 

Page ES-5, delete the 1 st paragraph beginning "Finally, the socioeconomic benefits. 

Page 1-1, Section 1.3, change heading "Purpose and Need for the Action" to "Benefits of the 
Action." 

Page 1-2, 1 st paragraph, change 1 st sentence to "The Project would provide a new source of 
electricity in a region where energy supplies may not be keeping up with the growth of 
demand." 

Page 1-2, end of 1 st paragraph, change last two sentences to: "That population and electrical 
demand growth, together with any retirement of older, less efficient, electrical generating 
units could require the continued development of new generation sources, along with energy 
conservation. The Project would fill a portion of need for additional generation." 

Page 1-2, 2 nd paragraph, change last 2 sentences to "While the demand for electricity has 
weakened somewhat since the economic downturn starting in late 2000, the demand for 



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Final Environmental Impact Statement Roundup Power Project 



power may continue its upward trend following economic recovery. This Project fits into the 
expected future economic growth and need for new sources of economical power." 

Page 1-5, 1 st paragraph, change 2 nd sentence to "The mine-mouth fuel source of the Project 
could provide stable pricing and reliability for base load power that may be needed by the 
utilities to reliably serve industrial, commercial, and residential customers." 

Page 1-5, Section 1.3.1, 1 st paragraph, change 1 st sentence to "A benefit of the Project could 
be a stable, reliable, low-cost supply of electricity in a region that has had uncertain supply 
and prices in recent years." 

Page 1-5, Section 1.3.1, 3 rd paragraph, change 2 nd sentence to "Montana would receive the 
investment, the tax-base increases, and the jobs that would be created by the construction, 
long-term operation of the facility, and the support systems and economic development." 

Page 1-7, Section 1.4, Table 1-1, delete "Section 106 of the National Historic Preservation 
Act" under the Permit/ Approval heading. Under Authority heading, change "National 
Historic Preservation Act" to "Montana Antiquities Act and Montana Environmental Policy 
Act." 

Page 2-40, Section 2.2.5, Cultural Resources subsection, CR-2, delete the phrase "in 
accordance with Section 106 of the NHPA ." 

Page 2-53, Section 2.4.2, second paragraph, replace the sentence beginning "Studies 
performed by both transmission providers. . ." with "Studies will be performed by both 
transmission providers to identify necessary upgrades to support this flow." 

Page 2-55, delete 3 rd full paragraph "Finally, the socioeconomic benefits. 

Page 3-4, Section 3.2.3, add the following sentence after the last sentence: "The town of 
Lame Deer, MT, a non-attainment area for PMi , is located southeast (downwind) of the 
Project." 

Page 3-55, Figure 3-7 Land Use, add label for Cole Road. See attached map at the end of this 
section. 

Page 3-74, Transportation subsection, first paragraph, delete the third sentence that begins 
"The Montana Department of Transportation does not attempt to justify. . ." 

Page 3-74, Transportation subsection, second paragraph and bulleted text, change SR 87 and 
SR 12 to US Route 87 and US Route 12, respectively. 

Page 4-10, Section 4.2.2, Table 4-6, replace the Proposed Emission Limit for S0 2 of "448.4 
(30-day rolling average)" with "482 lb/hr (24-hour basis)". 

Page 4-16, Section 4.2.1, paragraph number 2, replace the last sentence to read: "The closest 
federal non-mandatory Class I area is the Northern Cheyenne Reservation (NCR), located 
130 (81 miles) km southeast of the site." 

Page 4-17, 1st Full paragraph, add the following sentence to the end of that paragraph: "The 
10% change calculation is relative to the FLM's pristine background values for Class I areas 
in the Western United States." 



Chapter 5 5-2 Montana DEQ 



Roundup Power Project Final Environmental Impact Statement 



Page 4-98, Infrastructure Development Section, second paragraph, replace the paragraph 
beginning, "According to BPA, major transmission improvements..." with the following 
paragraph: 

BPA has a current project to increase capacity in Washington. However, this does not 
provide increased capacity from Montana to the Northwest. In order to provide 
service to the Roundup Power Project major facility additions will be required. This 
could potentially include substation upgrades and/or transmission line additions. 
Studies will be done in queue order based on BPA's long-term transmission request 
queue to determine the improvements needed. 

Page 7-2, Air Resources Section, add the following references: 

Dickey, J. W. Bull Mountain Development Co., LLC. 2002. Letter to Mr. Dan Walsh 
at MDEQ, December 30, 2002. 

Lorenzen, Diane, Lorenzen Engineering, Inc. 2002. Memo to Dan Walsh at 
MDEQ, November 21, 2002. 

Manson, Craig, Assistant Secretary for Fish and Wildlife, U.S. Fish and Wildlife 
Service, United States Department of the Interior. 2002. Letter to Ms. Jan 
Sensibaugh, Director of MDEQ, December 18, 2002. 

Page 7-9, Land Use Section, Change author of Fact Sheet: Facts At-A-Glance to 
"Musselshell County, Montana County Subdivisions and Planning." 

Page 8-2, add the following acronym and definitions: 

CALPUFF - modeling system proposed by the EPA as the refined modeling tool for 
analyzing long-range (beyond 50 kilometers) transport of pollutants and their impacts 
on Federal Class I areas. 

Page 8-3, add the following acronyms and definitions: 

FLAG - Federal Land Managers AQRV Work Group. An interagency workgroup 
whose objective is to achieve greater consistency in the procedures Federal Land 
Managers use in identifying and evaluating AQRVs (air quality related values). 

FLM - Federal Land Managers. 

Page 8-5, add the following acronym and definition: 

IMPROVE - Interagency Monitoring of Protected Visual Environments Program. 
Includes representatives from the NPS, FS, BLM, FWS, EPA and regional-state 
organizations. Activities include research on all aspects of the visibility issue. 

Page B-7, Appendix B, replace the paragraph preceding Table B-6 with the following 
paragraph: 

Impacts determined in the Scenario #2 cumulative visibility modeling conducted by 
the FLM are given in Table B-6 and Table B-6.1 using 1990 and 1992 meteorological 
data, respectively. Also included in these two tables are visibility impacts from the 
Project only. The FLM modeling included the facilities listed in Table B-l (seven 
other PSD sources and the Project) in the CALPUFF modeling analysis. 

Page B-7, Appendix B, replace Table B-6 with the following updated modeling results table: 



Montana DEQ 5-3 Chapter 5 



Final Environmental Impact Statement 



Roundup Power Project 



Table B-6 Visibility Impacts from the FLM 1990 Modeling Analysis 
The Project Visibility Impacts (without other PSD sources) 



Class I Area 


Change in Light 
Extinction 
(Days >5%) 


Change in Light 
Extinction 
(Days >10%) 


Maximum Change 
in Light Extinction 

(%) 


Yellowstone NP 


7 


1 


12.72% 


UL Bend WA 


4 





8.41% 


North Absaroka WA 


3 





9.11% 


Northern Cheyenne 


36 


11 


38.27% 



Cumulative Visibility Impacts (the Project with 7 other PSD Sources) 



Class I Area 


Change in Light 
Extinction 
(Days >5%) 


Change in Light 
Extinction 
(Days >10%) 


Maximum Change 
in Light Extinction 

(%) 


Yellowstone NP 


39 


26 


119.28% 


UL Bend WA 


50 


29 


156.50% 


North Absaroka WA 


35 


22 


126.83% 


Northern Cheyenne 


259 


224 


637.43% 



Source: National Park Service and US Fish and Wildlife Service, Dec. 18, 2002 . 
Note: CALPUFF modeling with 1990 meteorological data and maximum RH of 98%. 



Page B-7, Appendix B, add the following table of new modeling results conducted by the 
FLM after the revised Table B-6: 



Table B-6.1 Visibility Impacts from the FLM 1992 Modeling Analysis 



The Project Visibility Impacts (without other PSD sources) 



Class I Area 


Change in Light 
Extinction 
(Days >5%) 


Change in Light 
Extinction 
(Days >10%) 


Maximum Change in 
Light Extinction (%) 


Yellowstone NP 


13 


2 


15.41% 


UL Bend WA 


16 


4 


28.06% 


North Absaroka WA 


10 


1 


14.53% 


Northern Cheyenne 


32 


11 


46.87% 



Chapter 5 



5-4 



Montana DEQ 



Roundup Power Project 



Final Environmental Impact Statement 



Cumulative Visibility Impacts (the Project with 7 other PSD Sources) 



Class I Area 


Change in Light 
Extinction 
(Days >5%) 


Change in Light 
Extinction 
(Days >10%) 


Maximum Change in 
Light Extinction (%) 


Yellowstone NP 


32 


20 


83.67% 


UL Bend WA 


64 


41 


150.30% 


North Absaroka WA 


31 


21 


85.61% 


Northern Cheyenne 


286 


255 


971.98% 



Source: National Park Service and US Fish and Wildlife Service, Dec. 18, 200! . 

Note: CALPUFF modeling with 1992 meteorological data and maximum RH of 98%. 



Page B-12, Appendix B, insert at the end of the last paragraph the following two sections 
(Modeling Summary and Case by Case Analysis) including tables B-l 1 and B-12: 



Modeling Summary 



After the DEIS was published on November 18, 2002, the Proponent submitted 
CALPUFF modeling results to the DEQ and NPS for visibility impacts from the 
Project. (Lorenzen, November 21, 2002) The NPS had requested that the Proponent 
submit additional years of visibility modeling results. The Proponent had originally 
submitted 1992 visibility impact results to DEQ, but the Proponent had used seasonal 
relative humidity (RH) factors [F(RH)]. The NPS disagreed with using seasonal 
F(RH) data and requested that the Proponent use hourly RH data collected in 
Yellowstone National Park. 

The NPS used the data supplied to them by the Proponent to run 1992 visibility 
impacts. The NPS submitted CALPUFF 1992 modeling results in an attachment to a 
letter from the Department of Interior (DOI). (Manson, December 18, 2002) 

Table B-l 1 summarizes both the Proponent and NPS CALPUFF visibility modeling 
results that have been submitted covering the Project individually, or in a cumulative 
analysis. This table includes predicted visibility results previously provided in the 
DEIS and the 1992 visibility impacts submitted to DEQ after the DEIS was 
published. 

The modeling results from the NPS and the Proponent showed similar impacts from 
the Project, by itself. The cumulative results from the NPS and the Proponent are 
very different as their modeling protocols for a cumulative analysis differ 
significantly. 



Montana DEQ 



5-5 



Chapter 5 



Final Environmental Impact Statement 



Roundup Power Project 



Table B-ll Comparison of Modeling Results from the Proponent and NPS for 
Class I Area Visibility Impacts 



Modeling Scenario 


Parameters 


Scenario #1 


Scenario #2 


Scenario #3 


Modeling Analysis 


Proponent a 


Proponent c 


NPS 


NPS 


Proponent b 


Met Data Year 


1990 


1992 


1990 


1992 


1990 


Emissions 


Main Power Boiler 
(lbs/hr) 


NO x 


281 


281 


281 


281 


281 


so 2 


471 


471 


471 


471 


471 


so 4 


25 


25 


25 


25 


25 


PM 10 


60 


60 


60 


60 


60 


Fugitives and 
Baghouses (lbs/hr) 


PM 10 


3.7 


3.7 


3.7 


3.7 


3.7 


Class I Increment 


All Class I Areas 


NOx 


< 

Increment 


" 


< 

Increment 


" 


" 


S0 2 


< 

Increment 


" 


< 

Increment 


" 


" 


PM 10 


< 

Increment 




< 

Increment 


" 


" 


Class I Visibility (Proponent Only Analysis) 


Yellowstone 


>5% 


9 


15 


7 


13 


-- 


>10% 


1 


2 


1 


2 


-- 


Max 


13.0 


16.5 


12.7 


15.4 


-- 


UL Bend 


>5% 


4 


12 


4 


16 


-- 


>10% 





3 





4 


-- 


Max 


7.9 


20.6 


8.4 


28.1 


-- 


NAWA 


>5% 


6 


13 


3 


10 


-- 


>10% 


1 


2 





1 


-- 


Max 


11.1 


14.9 


9.1 


14.5 


-- 


NCIR 


>5% 


38 


-- 


36 


32 


-- 


>10% 


15 


-- 


11 


11 


-- 


Max 


41.0 


-- 


38.3 


46.9 


-- 


Class I Visibility (Cumulative Analysis) 


Yellowstone 


>5% 


15 


-- 


39 


32 


5 


>10% 


3 d 


-- 


26 


20 


4 tg 



Chapter 5 



5-6 



Montana DEQ 



Roundup Power Project 



Final Environmental Impact Statement 



Modeling Scenario 


Parameters 


Scenario #1 


Scenario #2 


Scenario #3 


Modeling Analysis 


Proponent a 


Proponent c 


NPS 


NPS 


Proponent b 


Met Data Year 


1990 


1992 


1990 


1992 


1990 




Max 


14.7 


-- 


119.3 


83.6 


15.7 


UL Bend 


>5% 


5 


-- 


50 


64 


6 


>10% 





-- 


29 


41 


5 g 


Max 


9.9 


-- 


149.5 


150.3 


117.7 


NAWA 


>5% 


12 


-- 


35 


31 


3 


>10% 


2 e 


-- 


22 


21 


3 d 


Max 


13.7 


-- 


125.8 


85.6 


18.51 


NCIR 


>5% 


-- 


-- 


259 


286 


-- 


>10% 


-- 


-- 


224 


255 


-- 


Max 


-- 


-- 


618.4 


972.0 


-- 



Notes: 

a The Proponent used a 1996 Baseline Date for including sources in the cumulative analysis. 

The Proponent used a 1975 Baseline Date for including sources and included negative emissions in the 
cumulative analysis. 

c Calculated with hourly RH data but excluded faulty Yellowstone RH values. 

Significant on at least two of the three days at the same receptors that have impacts above 10% change in light 
extinction. 

e Significant on both days and at the same receptors that have impacts above 10% change in light extinction. 

Significant on at least two of the four days but not at the same receptors that have impacts above 10% change in 
light extinction. 

8 Based on modeling results provided by the Proponent, Project significance levels could not be determined. 



Case-by-Case Analysis 



Due to the predicted high visibility impacts (>10%) from the Project, the Project 
Proponent felt that the NPS should perform a case-by-case analysis for each of the 
impacted days to provide further information about specific adverse impacts to any of 
the Class I areas. The Project Proponent felt that the NPS representing the DOI did 
not follow its own guidelines in the FLAG Phase I Report (12/2000) by performing a 
case-by -case analysis before reaching a decision of adverse impact on the Class I 
areas. 

The Assistant Secretary of the US Fish and Wildlife Service, on behalf of the DOI 
and the NPS, submitted a letter finding the Project would cause an adverse impact on 
Yellowstone National Park and UL Bend WA (Manson, December 18, 2002). A 
case-by -case analysis was not submitted as part of this letter. 

In response to the finding that the Project had an adverse impact, the Project 
Proponent prepared and submitted to the DEQ a case-by-case analysis on the daily 



Montana DEQ 



5-7 



Chapter 5 



Final Environmental Impact Statement Roundup Power Project 



impacts of the Project to Yellowstone National Park that were greater than 5% 
change in light extinction (Dickey, December 30, 2002). 

The Proponent has claimed that the high impacts that have occurred in the Class I 
areas have occurred on days with high humidity. Therefore, natural conditions (i.e., 
precipitation, fog, etc.) resulting from high humidity interfered with the natural 
background visibility and caused greater changes in light extinction than the impacts 
from the Project. 

A day-to-day analysis has been carried out for the specific days in 1990 and 1992 on 
which CALPUFF modeling indicated visibility impacts to Yellowstone National 
Park, due to the Project alone, in excess of 5% change in light extinction. Relevant 
data for these days are shown in Table B-12. 

The analysis utilized the most recent CALPUFF model results as submitted to DEQ 
and the NPS (Lorenzen, November, 21, 2002) for the Project. These modeling results 
are nearly similar to those obtained by the NPS. Since details of the NPS modeling 
were unavailable to the Proponent, all analysis was based on the Project modeling. 
Time periods analyzed are consistent with those used for the CALPUFF modeling. 

The first column of Table B- 1 1 shows natural background visibility for Yellowstone 
National Park per FLAG data, taking account of the mean daily relative humidity 
(RH) factor [F(RH)] as incorporated in CALPUFF meteorological data. The second 
column lists the modified visual range when model-predicted light extinction due to 
the Project is added to natural background. The percent change in light extinction 
(compared to theoretical natural conditions) due to the Project, as predicted by 
CALPUFF, is given in the third column. 

Measured visibility at the Yellowstone National Park IMPROVE (Interagency 
Monitoring of Protected Visual Environments Program) monitoring station is shown 
in Column 4. The tabulated values of visual range correspond to the 24-hour average 
measured light extinction for the day. The following column shows the percentage 
change in light extinction (compared to actual measured extinction) due to the model- 
predicted Project impact for each day. 

The last three columns of Table B-12 summarize information from the IMPROVE 
monitoring site as provided in data reports. Light extinction data are noted as 
"interference" if extinction values are very high or change rapidly from hour-to-hour, 
or if site-specific RH exceeds 90%. This classification is intended to indicate that the 
measured light extinction was likely affected by natural visibility impairment (fog, 
precipitation, clouds). The number of hours of interference is listed in the table, as 
well as the number of hours each day that the measured light extinction was 100 per 
10" 6 meters (Mm 1 ) or greater, and the site RH was greater than 90%. A background 
light extinction (b ext ) value of 100 Mm" 1 is taken as an arbitrary but conservative 
indicator of significant natural visibility impairment. 



Chapter 5 5-8 Montana DEQ 



Roundup Power Project 



Final Environmental Impact Statement 



Table B-12 Modeled and Measured Yellowstone Visibility Data (Days with 
Predicted Impacts Greater than 5% Change in Light Extinction) 







Visual 
















Natural 


Range 




Measured 




#of 


#of 


#of 




Background 


with 


% 


Back- 


% 


Inter- 


Hours 


Hours 




Visual 


Roundup 


Change 


ground 


Change 


ference 


with b ext 


RH> 


Date 


Range (km) 


(km) 


in b ext 


(km) 


in b ext 


Hours 


>100 


90 



1990 Impacts 



01/15/90 


205 


189 


8.22 


12 


0.47 


24 


17 


5 


01/16/90 


202 


191 


5.66 


17 


0.48 


22 


9 


4 


03/05/90 


241 


214 


12.86 


10 


0.56 


22 


18 


16 


03/23/90 


245 


231 


5.81 


15 


0.34 


18 


15 





04/05/90 


253 


239 


6.03 


153 


3.65 











07/19/90 


251 


237 


5.59 


96 


2.13 


9 


1 


3 


07/20/90 


241 


220 


9.63 


75 


3.00 


11 


3 


2 


09/28/90 


249 


233 


7.14 


91 


2.61 


7 





7 


10/06/90 


238 


226 


5.31 


14 


0.32 


19 


10 


14 



1992 Impacts 



03/05/92 


242 


228 


5.72 


92 


2.17 


14 





8 


03/08/92 


228 


214 


6.83 


58 


1.74 


8 


2 


5 


03/18/92 


224 


204 


9.86 


18 


0.78 


13 


8 


12 


04/11/92 


220 


204 


7.97 


54 


1.95 


15 


4 


14 


05/21/92 


207 


197 


5.11 


116 


2.86 


19 





7 


06/15/92 


202 


189 


7.16 


23 


0.80 


24 


17 


23 


07/20/92 


239 


222 


7.60 


43 


1.37 


16 


6 


13 


07/21/92 


215 


200 


7.45 


116 


4.04 


20 


1 


13 


07/22/92 


226 


213 


5.94 


69 


1.82 


11 


2 


10 


08/23/92 


236 


214 


10.31 


86 


3.78 


13 


1 


7 


08/24/92 


238 


205 


16.45 


123 


8.47 


5 


1 


4 


08/25/92 


242 


225 


7.57 


142 


4.45 


4 





4 


10/15/92 


221 


206 


6.91 


23 


0.71 


15 


5 


10 


12/03/92 


243 


232 


5.01 


38 


0.77 


11 


5 





12/12/92 


203 


192 


5.57 


65 


1.79 


8 


1 


5 



Source: Dickey, LLC, December 30, 2002. 



Montana DEQ 



5-9 



Chapter 5 



Final Environmental Impact Statement Roundup Power Project 

Conclusions and Observations from the Case-by- 
Case Analysis 

The Proponent believes that the U.S. Assistant Secretary for FWS has made an 
adverse impact decision without sufficient information by not completing a case-by- 
case analysis. The Proponent provided the following conclusions and observations 
from a case-by-case analysis supporting their position that no adverse impact occurs 
at Yellowstone National Park from the Project (Dickey, December 30, 2002): 

• On the vast majority of days of predicted Project impact, actual visibility at 
the Yellowstone National Park IMPROVE site was highly impacted by 
natural weather conditions, with many hours of the day classified as 
"interference." 

• When the model-predicted light extinction for the Project is compared to 
actual visibility, the percent change in light extinction was less than 5% on 
23 of the 24 days. The single day with >5% impact (8/24/92) had only 5 
hours of indicated weather interference, but the daily F(RH) value 
corresponds to RH of 84%, indicative of extensive low cloudiness on an 
August day. The occurrence of regional clouds and precipitation on this day 
was confirmed by reference to synoptic weather maps. 

• The overall results strongly support the Proponent's assertion that days of 
potential Project impact at Yellowstone National Park are highly correlated 
with the occurrence of precipitation and generally adverse weather conditions 
that cause natural visibility impairment. This conclusion follows from the 
association of the Project impacts with northeasterly winds and a synoptic 
weather situation marked by low pressure to the south of Yellowstone 
National Park. 

• For the 24 days listed in Table B-l 1, the mean F(RH) was 4.373, implying an 
RH of 89%. This further supports the indication that predicted Project 
impacts are highly correlated with natural conditions of fog, precipitation, 
and clouds. 

• There is no indication of Project impacts during days of clear, high visibility 
conditions when actual impacts would be discernible by park visitors. 
Therefore, the modeled light extinction changes do not represent a significant 
impact (adverse effect) on viewing conditions due to Project emissions. 

• Similar case-by-case analyses could not be provided for the UL Bend and 
North Absaroka wilderness areas because no IMPROVE data is available for 
these Class I areas. However, the Proponent noted that on the highest 
visibility impact day (1 1/18/92) for the UL Bend WA, the daily F(RH) 
corresponded to an RH greater than 94%, based on Glasgow, Montana 
surface data. The two other days with predicted impacts greater than 10% at 
the UL Bend WA had nighttime RH values of 80% or higher. Thus, the 
predicted visibility impacts are again a direct result of high RH when natural 
visibility impairment in valley locations such as UL Bend WA is likely 
(Dickey, December 30, 2002). 



Chapters 5-10 Montana DEQ 




Figure 3-7 



Land Use 



Roundup Power Project FEIS 



Legend 



□ Residence 



M Non-Residential Structure 



Preliminary Transfer Location 



Fence Line 



H 1 1 



Proposed Railroad 



State Highway 



Local Road 



Dirt Road 



Section Line 



River / Stream 



1" : 1,250' 
625 1,250 



2,500 Feet 




>£- Montana Department of 

lEnVIROXMEmi.Qi.Al. 



N 




W:\Env_Roundup\Apps\Landuse.mxd 



13122502 Landuse Rev2 010603 AAA 



Roundup Power Project Final Environmental Impact Statement 

Appendix A 

Letters from Local, State and Federal Agencies and 

Tribes 



Montana DEQ A-l Appendices 




df** '^Ota i&y ~4r*!4tn&y 

MONTANA HOUSE OF REPRESENTATIVES 

RECEIVED 

REPRESENTATIVE ALAN OLSON <»■- wi-i v i_i-r 

HOUSE DISTRICT 8 ___ „ 

DEC 1 8 2002 

COMMrTTEEB: HELENA ADDRESS: 

EDUCATION POBOX20OW0 

snmMHMBnwnoN DEPT. OF ENVIRONMENTAL QUALITY HELENAl "— ""' S)S3Mi400 

FEDERAL, ENERGY. TELECOMMUNICATIONS ' PHONE: («S) +44-4800 

HOME. .J: 

December 18, 2002 ^ybSEE? 

PHONE (409)323-3341 

Mr. Greg Hallsten 

P.O. Box 200901 

Helena, Montana 59620-0901 

Dear Mr. Hallsten, 

I am writing to comment on the Draft Environmental Impact Statement for the proposed 
Roundup Power Project 

First of all I would like to thank you and the others involved in drafting the document for 
the hours spent in ensuring the public and government agencies have a reasonable 
document to work with in determining the impacts of the Roundup Power Project. 

The first concern I would like to address is the impact on water resources. The draft 
document is accurate in its description on the aquifers in the area. Potential impacU to 
residents in the area, from withdrawal of water from the Madison formation would be 
virtually non-existent with a properly constructed well casing program. Casing, cemented 
bade to surface, set through reasonably accessible ground water zones would protect the 
various aquifers in the Tongue River member of the Fort Union Formation from 
contamination, either from Madison Formation water due to artesian flow or 
contamination due to communication from other water sands or coal seams. Additional 
casing would be run to approximate total well depth and cemented, not necessarily to 
surface, to protect not only the well bore but also to prevent mixing of other aquifers. 
Generally, this is standard practice in wells such as these. 

On page 3-77 of the document it states there is a "perception" residents of the Bull 
Mountain Community, mini-farmers, are opposed to coal development During the 
scoping meeting and the public hearing on December S*' numerous residents of the Bull 
Mountains came forward and testified in favor of this project. 1 do not recall any verbal 
opposition at either of theae public meetings from residents of the Bull Mountains. I too 
am a part of the Bull Mountain Community. Discussions with my neighbors have 
generated total support for this project 



As for visibility concerns of the Federal Land Managers addressed on pages 4-1 03 and 
Appendix B-4, B-7, 1 have to question why the FLMs would include air quality dam from 
sources that no longer exist such as die Anaconda smelter. How would operations sue J as 
Colstrip, non-existent Anaconda smelter, and the Roundup project, all affect Yellowstone 
Pack at the same time? Is there an air model on the impact of the annual fires in 
Yellowstone and surrounding area, and if so how does that compare to the projected loss 
of visibility from the Roundup project? With Colstrip to the east and Roundup to the 
northeast of Yellowstone Park, what weather patterns associated with flow in the parks 
direction lead to a loss in visibility, as east winds are generally associated with inclement 
weather? 



There is no doubt this project will have an impact on the environment Every day, every 
om —- — i Ike environment Evsry new car, subdivision, agriculture operation, cottage 
business, and tourist hat an impact on the environment The p ~ ive economic impacts 
associated with this project amount to a compelling state interest. The lack of good 
paying jobs and die inability to raise revenue for local and state government programs 
due to die decline of tax base and tax payers make this an issue of compelling state 
interest 

Once again, thank you for your time and efforts on this project 

Sincerely, 



Alan Olson 




Department of Energy 

Bonneville Power Administration 

P.O. Box 61409 

Vancouver, WA 98666-1409 



TRANSMISSION BUSINESS LINE 

January 3, 2003 

In reply refer to: TOP/PP02-2 

Mr. Greg Hallsten 

Montana Department of Environmental Quality 

P.O. Box 200901 

Helena, MT 59620-0901 

Dear Mr. Hallsten: 

I am writing in regards to the Roundup Power Project Draft Environmental Impact Statement 
(DEIS). Although formal comments were due by December 1 8, 2002, 1 understand we are still 
able to submit comments to this report. 

The Roundup Power Project developer has requested transmission service from the Bonneville 
Power Administration Transmission (BPAT) through the Open Access Transmission Tariff 
process. This secures their position in BPAT's long-term transmission request queue. The 
general process is as follows: 

1 . Long-term firm transmission service is requested. 

2. If the transmission provider determines a System Impact Study (SIS) is required an SIS 
agreement is executed. The SIS is a general study to identify any system constraints and the 
general scope of network upgrades required to provide the requested firm transmission 
service. 

3. When the SIS is completed and if the requestor decides to move forward a System Facility 
Study (SFS) agreement is executed. The SFS is a more detailed study to determine specific 
facility additions, upgrades, and/or remedial action schemes required to provide the requested 
firm transmission service. This includes estimated cost and construction schedule. 

4. When the SFS is completed and the requestor decides to move forward, a Construction 
Agreement is executed, pending completion of any required environmental studies and 
analyses. 

5. Upon completion of the SFS and any required construction and environmental analyses, a 
transmission service agreement will be offered to the requesting entity. 

This process is described in more detail in BPAT's Open Access Transmission Tariff. Since 
there are several transmission requests ahead of the Roundup Power Project in BPAT's long- 
term transmission request queue, and requests must be considered in queue order, the SIS is 
expected to be completed in the fourth quarter of 2003. After the SIS is completed it is estimated 
the SFS could take an additional 4-6 months depending on the scope of network upgrades 
identified. 



1 



The first comment on the Roundup Power Project DEIS is in Section 2.4.2, 230kV Transmission 
System Alternative, page 2-53, second paragraph. The last sentence states, "Studies performed 
by both transmission providers have identified upgrades that are proposed and underway to 
support this flow." I suggest the following alternative. "Studies will be performed by both 
transmission providers to identify necessary upgrades to support this flow." 

The second comment is in the section titled Infrastructure Development, Transmission, Page 4- 
98, second paragraph. This paragraph states, "According to BPA, major transmission 
improvements to the BPA system are planned. These improvements would include substation 
upgrades and transmission line additions between Montana and the Pacific Northwest." I 
suggest the following alternative. "BPAT has a current project to increase the West-of-Hatwai 
cutplane capacity in Washington. However, this does not provide increased capacity from 
Montana to the Northwest. In order to provide service to the Roundup Power Project major 
facility additions will be required. This could potentially include substation upgrades and/or 
transmission line additions. Studies will be done in queue order based on BPAT's long-term 
transmission request queue to determine the improvements needed." 

If you have any questions or comments, please call me at (360) 619-6668. 

Sincerely, 



Charles E. Matthews 

Process Manager, Network Planning 




iana Deportment of Transportation 



David A. Gait Director 



2701 Prospect Avenue 

PO Box 201001 

Helena MT 59620-1001 



November 22, 2002 



Greg Hallsten 

Montana Department of Environmental Quality 

P.O. Box 200901 

Helena, Montana 59620-0901 



Judy Martz, Governor 



NOV % 5 2002 



MTDEPT.OFENV.QUAUTY 
PBMTTING & COMPLIANCE DM 



Subject Roundup ?QWgr Project-Draft Fnvironrnemal Impact Statement 

Greg, 

We have reviewed primarily transportation issues in the subject document and 

have the following comments: 

■ The meaning or intent of the third sentence in the first paragraph on 
page 3-74 that begins "The Montana Department of Transportation 
does not attempt to justify. . ." is not clear. A better explanation of what 
is intended should be provided or the sentence deleted. 

■ Additionally, in the second paragraph on page 3-74 US Route 87and US 
Route 12 are referred to as SR 87 and SR 12. If this SR is identifying 
the roadways as "State Routes" it is incorrect They are both US 
Routes. 

If you have any questions please contact me at (406) 444-6303. Thanks 




Dan Martin, Planner 

Program & Policy Analysis Bureau 

Rail, Transit and Planning Division 

copies: Patricia Saindon, Administrator, Rail, Transit and Planning Division 
Bruce Barrett, Administrator, Billings District 
Sandra Straehl, Program and Policy Analysis Bureau Chief 



Program & Policy Analysis Bureau 
Phone: (406)444-3423 



An Equal Opportunity Employer 



Ran, Transit and Planning DMsfon 
TTY: (800)335-7592 

U/ah Dana* muu/ ms4t- r- hat-a mt- uw 




United States Department of the Interior RECEIVED 

OFFICE OF THE SECRETARY n _ p 

Washington, D.C. 20240 UtU 3 2002 

DEQ 

December 18, 2002 DIRFrro»* c nspfrr 



Ms. Jan Sensibaugh 

Director, Montana Department of Environmental Quality 

P.O. Box 200901 

Helena, MT 59620-0901 

Dear Ms. Sensibaugh: 

The National Park Service (NPS) and U.S. Fish and Wildlife Service (FWS) have been 
participating in the Clean Air Act (CAA) "Prevention of Significant Deterioration" (PSD) 
permit review for the construction and operation of the Roundup Power Project (RPP) 
since January 2002. 

The proposed RPP would be a 780 Megawatt, coal-fired, electric generating station located 
approximately 180 km northeast of Yellowstone National Park (NP) and 122 km south of 
UL Bend Wilderness Area (WA). Under the Clean Air Act, both Yellowstone NP 
(administered by the NPS) and UL Bend WA (administered by the FWS) are designated as 
"Class I" air quality areas. The CAA gives Federal Land Managers an affirmative 
responsibility to protect air quality related values (including visibility) of these areas, and to 
consider whether any major emitting facilities will have an adverse impact on such values 
42 USC 7475(d)(2)(B). We have concluded that if constructed and operated under the 
conditions outlined in your Preliminary Determination and draft permit, RPP's proposed 
emissions - when analyzed alone and in combination with existing emissions in the area - 
could cause perceptible visibility impairment at Yellowstone NP and UL Bend WA. Based 
on our analysis, we believe emissions from RPP will have an adverse impact on park air 
quality related values, and we ask the MT DEQ, pursuant to 42 USC 7475(d)(2)(C)(ii) to 
consider our concerns on the record in making a determination. Enclosed are detailed 
comments that support our adverse impact finding. 

RPP is a modern, well-planned facility. It will be cleaner than nearly all of its predecessors. 
The adverse impact comes from the fact that RPP will contribute to concentrations which 
cause an adverse effect at Yellowstone NP and UL Bend WA, two Class I areas. We 
would welcome the opportunity to discuss this and other approaches with you and other 
environmental regulators in the region, as well as with permit applicants and other 
interested stakeholders, as you deem appropriate. Perhaps we could first explore a full 
range of options and discuss possible approaches with you and your staff, before we begin a 
more formal multi-stakeholder approach. We recently proposed a similar approach 
regarding a permit action in the State of Wyoming. 



In closing, in the spirit of Secretary Norton's "Four C's" process of "consultation, 

cooperation, communication, all in the service of conservation," we solicit your help in 

resolving our concerns about the RPP project and fulfilling our mutual obligations under 

the Clean Air Act to protect the air quality in these special areas for the enjoyment of future 

generations. By working together we are hopeful that we can protect the visibility at 

Yellowstone NP and UL Bend WA. If there are any questions regarding this matter, please 

contact Christine Shaver of the NPS Air Resources Division at (303) 969-2074, or Sandra i 

Silva of the FWS Air Quality Branch at (303) 969-2814. j 

Sincerely, I 



Craig Sanson v 

Assistant Secretary for Fish and Wildlife 
Fish and Wildlife and Parks 



Enclosure 
cc: 

Richard Long 

U.S. Environmental Protection Agency 
Mail Code HP-AR 
999 18 th St., Suite 300 
Denver, Colorado 80202-2466 

Jay Littlewolf 

Air Quality Division 

Northern Cheyenne Tribe 

P.O. Box 128 

Lame Deer, Montana 59043 

Ann Acheson 

USDA Forest Service, Region 1 

P.O. Box 7669 

Missoula, Montana 59807 



Determination of Adverse Impact to Visibility at Yellowstone National Park and UL Bend 
Wilderness Area for the Roundup Power Project 

by 

U.S. Department of the Interior 

December 2, 2002 

Background 

Roundup Power is proposing to construct a new power plant consisting of two, 390 Megawatt, 
pulverized coal-fired boilers. The proposed facility would be located next to the Bull Mountains 
Coal Mine in south-central Montana in Musselshell County, near the town of Roundup. This 
location is approximately 122 km south of UL Bend Wilderness Area (WA) and 180 km northeast 
of Yellowstone National Park (NP), Class I air quality areas administered by the U.S. Fish and 
Wildlife Service (FWS) and the National Park Service (NPS), respectively. This project would 
result in Prevention of Significant Deterioration (PSD) significant increases in emissions of 
nitrogen oxides (NOx), sulfur dioxide (S0 2 ), particulate matter (PMio), volatile organic compounds 
(VOC), and carbon monoxide (CO). Emissions (in tons per year - TPY) are summarized below. 



POLLUTANT 


EMISSIONS (TPY) 


NOx 


2329 


S0 2 


3939 


PMio 


512 


VOC 


99 


CO 


4917 



The NPS Air Resources Division and the FWS Air Quality Branch received the PSD permit 
application for the Roundup Power Project (RPP) in January 2002. On February 19, 2002, a 
Technical Analysis outlining the comments of both NPS and FWS offices was jointly submitted 
to the Montana Department of Environmental Quality (MT DEQ). This Technical Analysis 
presented comments and recommendations regarding Best Available Control Technology 
(BACT) and the air quality modeling analysis submitted with the RPP PSD application. Due to 
errors discovered with data used in the air quality modeling, a revised air quality analysis was 
submitted by RPP on April 22, 2002. After reviewing the results, a second comment letter was 
sent to MT DEQ by NPS and FWS on May 6, 2002. In this letter, we notified MT DEQ that 
based upon the results in the air quality analysis, the RPP facility had the potential to have an 
adverse impact to visibility at Yellowstone NP and UL Bend WA. 

On August 12, 2002, MT DEQ released the Preliminary Determination on Permit Application 
for the Roundup Power Project. Using the emission rates outlined in this draft permit and the 
1990 meteorological data supplied by RPP, we performed additional modeling to assess potential 
impacts at Yellowstone NP and UL Bend WA, if RPP operated under the conditions outlined in 
the draft permit. Our results again indicated that potential adverse visibility impacts might occur 
from RPP's emissions alone, and when RPP's emissions are combined with other PSD sources in 
the area. On August 27 we sent a third comment letter to MT DEQ that repeated our concern 
that potential adverse impacts could occur at Yellowstone NP and UL Bend WA. We again 
requested that RPP conduct additional modeling with an additional year of meteorological data 
(1 992) to better define the impacts at these areas. 



On October 28, RPP submitted the SO2 increment analysis and the cumulative visibility analysis 
that we requested in our previous letters. The results indicate that the SO2 increment will not be 
violated at Yellowstone NP or UL Bend WA, and we agreed with these results. However, in 
conducting the cumulative visibility analysis with the 1990 data, RPP used a modeling 
methodology we do not consider valid. This approach is considered invalid because it excludes 
several large sources, including many that RPP included in the SO2 increment analysis. We 
conducted a separate modeling analysis using the correct number of sources. This modeling 
found an extremely high number of days when there would be perceptible visibility impacts, and 
shows that RPP would be a significantly contributing source on those days. These modeling 
results and concerns were again presented in a fourth letter to MT DEQ on November 6, 2002. 

On November 18, MT DEQ released the Draft Environmental Impact Statement (DEIS) for this 
project. The DEIS presents multiple modeling results that have been submitted by both RPP and 
NPS/FWS. NPS/FWS modeling results submitted in our November 6, 2002, letter to MT DEQ 
were presented in Scenario 2 (Table B-6) of the DEIS. On December 2, 2002, the NPS/FWS 
discovered a small modeling error associated with these results. The NPS/FWS modeling results 
calculated visibility impacts from hour 1 to hour in the modeling post-processor instead of 
from hour to hour 23. This results in small changes in predicted impacts. The new results are 
presented below in Tables 1 and 2. The results also confirm our concern that RPP in combination 
with other PSD sources in the area would adversely impact visibility at both Yellowstone NP and 
UL Bend WA. Please note that the North Absaroka and Northern Cheyenne Class I areas are not 
administered by the Department of the Interior. However, we have included these areas in our 
modeling analyses for completeness. 



Table 1-RFP only 
Results of December 2, 2002, NPS/FWS modeling for the proposed Roundup Power Plant. Should replace 
those presented in November 6, 2002, letter to MT DEQ and published as Table B-6 in RPP Draft 
Environmental Impact Statement. 



RPP VISIBILITY IMPACT by NPS/FWS with STATE PROPOSED EMISSION LEVflTS- 
1990 Meteorological Data with f(RH) Max = 98% 


Area 


Days >5% 
Change in Extinction 


Days >10% 
Change in Extinction 


Maximum Change in 

Extinction 


Yellowstone NP 


7 


1 


12.72 % 


UL Bend WA 


4 





8.41% 


North Absaroka WA 


3 





9.11% 


Northern Cheyenne 


36 


11 


38.27% 



Table 2 - Cumulative Sources 
Results of December 2, 2002, NPS/FWS cumulative ility modeling for the proposed Roundup Power 
Plant and 7 PSD sources. Should replace those presented in November 6, 2002, letter to M T DEQ and 
published as Table B-6 in RPP Draft Environmental Impact Statement. 



RPP with STATE PROPOSED EMISSION LIMITS + 7 PSD SOURCES VISIBILITY 
IMPACT by NPS/FWS - 1990 Meteorological Data with f(RH) Max = 98% 



Area 



Days >5% 
Change in Extinction 



Days >10% 
Change in Extinction 



Maximum Change in 
Extinction 



Yellowstone NP 



39 



26 



119.28 % 



UL Bend WA 



50 



29 



149.50% 



North Absaroka WA 



35 



22 



125.83 % 



Northern Cheyenne 



259 



224 



618.43% 



As noted in Tables 1 and 2, these analyses were based on 1990 meteorological data. Following 
publication of the DEIS, additional modeling of RPP-only impacts using 1992 meteorological 
data was submitted by RPP (November 21, 2002, letter to D. Walsh, MT DEQ, from D. 
Lorenzen). The NPS and FWS were unable to replicate the RPP results exactly, but the results 
are very similar. RPP did not submit a cumulative visibility analysis using 1992 data, so the 
NPS/FWS performed this analysis using the source inventory supplied by RPP for the 1990 
analysis. The NPS/FWS results using the 1992 data are presented below in Tables 3 and 4. 



Table3-RPPonIv 
Results of NPS/FWS modeling for the proposed Roundup Power Plant 


using 1992 data. 


RPP VISIBILITY IMPACT by NPS/FWS with STATE PROPOSED EMISSION LIM1TS- 
1992 Meteorological Data with f(RH) Max = 98% 


AREA 


Days >5% 
Change in Extinction 


Days >10% 
Change in Extinction 


Maximum Change in 
Extinction 


Yellowstone NP 


13 


2 


15.41% 


UL Bend WA 


16 


4 


28.06% 


North Absaroka WA 


10 


1 


14.53% 


Northern Cheyenne 


32 


11 


46.87% 



Table 4 - C ative Sources 
Results of NPS/FWS cumulative visibility modeling for the proposed Roundup Power Plant and 7 PSD 
sources using 1992 data. 



RPP with STATE PROPOSED EMISSION LIMITS + 7 PSD SOURCES VISIBILITY 
IMPACT by NPS/FWS - 1992 Meteorological Data with f(RH) Max = 98% 


AREA 


Days >5% 
Change in Extinction 


Days >10% 
Change in Extinction 


Maximum Change in 
Extinction 


Yellowstone NP 


32 


20 


83.67% 


UL Bend WA 


64 


41 


150.30% 


North Absaroka WA 


31 


21 


85.61% 


Northern Cheyenne 


286 


255 


971.98% 



Discussion of Modeling Results and Air Quality Impacts 

A 10% change in extinction is the generally accepted level that would be perceptible to the 

casual observer. A 5% change could be perceptible for a particular scene under special visibility 

conditions. 



During this review process, both RPP and NPS/FWS have submitted numerous modeling results. 
While the magnitude of visibility impacts vary slightly, the general trend is that RPP alone would 
cause perceptible visibility impacts at Yellowstone NP and UL Bend WA. This is shown in 
Tables 1 and 3. In the November 6, 2002, letter to MT DEQ, the NPS and FWS stated that based 
on the results of the 1990 RPP-only analysis, the FWS would not consider the impacts caused by 
RPP alone to be adverse, but that additional modeling may produce different results. Based upon 
the results now available for the 1992 analysis (Table 3), the impacts from RPP alone would also 
have an adverse impact on visibility at UL Bend WA. 

These RPP-only modeling results also trigger a cumulative visibility analysis for both Class I 
areas. These cumulative impacts (Tables 2 and 4) are severe in both frequency and magnitude, 
and constitute an adverse impact at both areas. Moreover, RPP would be a significant contributor 
to these impacts. These results indicate that RPP has not met the demonstration required under 
the Administrative Rules of Montana, which require the owner or operator to demonstrate that 
the RPP ". . .will not cause or contribute to adverse impact on visibility within any federal Class 
I area or the department will not issue a permit." (17.8.1 106(1)) (emphasis added). 

The 1992 results presented in Tables 3 and 4 demonstrate that the 1990 impacts (Tables 1 and 2) 
are not isolated events, and the RPP would continue to cause and contribute to adverse visibility 
impacts over time. These results further confirm the NPS/FWS finding that the RPP project 



would cause and significantly contribute to adverse visibility impacts and cumulative visibility 
impacts at Yellowstone NP and UL Bend WA. 

RPP and the MT DEQ have raised the issue as to whether RPP's contribution to the adverse 
cumulative visibility impacts are "significant." A review of the modeling outputs for the 1990 
RPP -only and for the 1990 cumulative visibility impacts was done by the NPS/FWS to examine 
this issue. The results demonstrate that RPP's contributions on days in which the cumulative 
visibility impacts exceed 10% at Yellowstone NP and UL Bend WA are indeed significant. For 
instance, on Day #15 at receptor #33, the cumulative change in extinction is 12.24%. On that 
same day and at the same receptor, the change in extinction caused by RPP alone is 6.77%, or 
55% of the total cumulative visibility impact. On Day #16 at receptor #33, the cumulative 
change in extinction is 14.32%. The extinction caused by RPP alone on this date and receptor is 
6.33%, representing 44% of the cumulative visibility impact. Similarly, for UL Bend WA, on 
day #46 at receptor #351, RPP's contribution was 8.41% of the total 29.18% change in extinction 
(29%). Our review of both the 1990 and 1992 results shows many additional instances when RPP 
represents a significant percentage of a cumulative change in extinction that is greater than 10% 
change in extinction at Yellowstone NP and UL Bend WA. 

Adverse Impact Demonstration 

Under the regulations promulgated for visibility protection (40 CFR §51.301) visibility 
impairment is defined as ". . .any humanly perceptible change in visibility (visual range, contrast, 
coloration) from that which would have existed under natural conditions." The threshold for 
perceptibility, where a just noticeable change occurs in the scene, has been found to correspond 
to a change in extinction as low as 2% under ideal conditions. A change in extinction will evoke 
a just noticeable change in most landscape, and FLMs consider a change in extinction greater 
than 10% to be unacceptable, unless there is mitigation. 

In 1872, the enabling legislation that established Yellowstone NP as the world's first national 
park states that the Yellowstone NP 

".. .is hereby reserved and withdrawn from settlement, occupancy or sale under the laws 
of the United States, and dedicated and set apart as a public park or pleasuring-ground for 
the benefit and enjoyment of the people." (17 Stat. 32) 

Scenery and visibility play a critical role in the quality of visitor experience, and visitors to 
national parks and wildernesses list the ability to view unobscured views as a significant part of a 
satisfying experience. The enjoyment and appreciation of Yellowstone NP and UL Bend WA are 
linked to the ability of visitors to view the scenery clearly. A significant reduction in visibility 
would hinder the benefits and enjoyment of visitors to Yellowstone NP and UL Bend WA, as 
well as diminish the national significance of these majestic landscapes. Air pollution currently 
impairs visibility to some degree in every national park and refuge, increasing the importance of 
preventing additional impairment. Visibility impacts from the RPP alone would cause a 
significant change in extinction that would hinder the benefits and enjoyment of visitors to 
Yellowstone NP and UL Bend WA on the days those impacts occur. The emissions from RPP 
would also significantly contribute to the more frequent and severe cumulative visibility impacts 
that occur at both Yellowstone NP and UL Bend WA. 



The Federal Land Manager considers impacts to air quality related values such as visibility to be 
adverse if such impacts would impair the quality of the visitor experience or diminish the area's 
national significance. This is consistent with the Code of Federal Regulations (CFR) which 
defines an adverse impact on visibility as "visibility impairment which interferes with the 
management, protection, preservation, or enjoyment of a visitor's visual experience of a Federal 
Class I area. This determination must be made on a case-by-case basis taking into account the 
geographic extent, intensity, duration, frequency, and time of visibility impairments, and how 
these factors correlate with (1) times of visitor use of the Class I area, and (2) the frequency and 
timing of natural conditions that reduce visibility." (40 CFR §51.300, et seq. §52.57) 

The Administrative Rules of Montana also give a similar definition, stating that "adverse impact 
on visibility means visibility impairment which the department determines does or is likely to 
interfere with the management, protection, preservation, or enjoyment of the visual experience of 
visitors within a federal Class I area. The determination must be made on a case-by-case basis 
taking into account the geographic extent, intensity, duration, frequency, and time of visibility 
impairment, and how these factors correlate with times of visitor use of the federal Class I area, 
and the frequency and occurrence of natural conditions that reduce visibility" (17.8.1101(2)). 
These definitions support our position that perceptible visibility impacts of the frequency and 
magnitude of those predicted for RPP are indeed adverse. 

With respect to the relationship of visibility impacts and times of visitor use of the Class I areas, 
Yellowstone NP and UL Bend WA are both open to visitor use 24 hours a day, year-round. Thus 
visitation can and does occur at any time. There were nearly three million recreational visits to 
Yellowstone NP during 2001. For many visitors this is a once-in-a-lifetime experience, and the 
NPS and FWS are greatly concerned that the experience of each and every visitor not be 
interfered with by adverse visibility impairment on any day(s) in which visitation occurs. 
Regarding natural conditions that reduce visibility, RPP has stated that the 1990 impact that is 
greater than 10% occurs during a snowstorm and that a park visitor 1) would not be out in the 
elements to view the scenery with any expectation of seeing vast distances and 2) the natural 
background impairment of the snowstorm would far outweigh the impact of RPP (October 21, 
2002, letter to D. Walsh, MT DEQ, from J.W. Dickey). This argument is flawed because it 
assumes that the snowstorm would be occurring throughout the entire 1.1 million hectare area of 
Yellowstone NP, and would affect all visitors present in the park at that time. Further, it is 
unlikely that this weather condition would persist throughout the entire period that is modeled. 

Congress recognized the importance of visibility in national parks and wilderness areas when it 
amended the Clean Air Act (CAA) in 1977 and established a national goal of preventing any 
future visibility impairment, and remedying any existing visibility impairment due to human- 
caused air pollution in areas such as Yellowstone NP and UL Bend WA. The CAA directs that 
the FLMs identify and protect air quality related values, including visibility. In the case of the 
CAA the FLM gleans additional insight from a passage in Senate Report No. 95-127, 95 th 
Congress, 1 st Session, 1977 which states, 

"The Federal Land Manager holds a powerful tool. He is required to protect Federal lands 
from deterioration of an established values, even when Class I [increments] are not 



exceeded. ...While the general scope of the Federal Government's activities in 
preventing significant deterioration has been carefully limited, the FLM should assume 
an aggressive role in protecting the air quality values of land areas under their 
jurisdiction. In cases of doubt the land manager should err on the side of protecting the 
air quality-related values for future generations." 

Conclusions 

We have stated our concern about potential impacts resulting from the RPP facility in four 
comment letters to MT DEQ. Three of these letters clearly identify the potential for adverse 
impacts at Yellowstone NP and UL Bend WA. Attempts have been made in two conference calls 
and in numerous informal communications to resolve issues with RPP and MT DEQ. Modeling 
analyses submitted by both RPP and the NPS/FWS have repeatedly indicated that RPP will have 
an adverse impact on visibility at Yellowstone NP and UL Bend WA. The RPP would also 
significantly contribute to adverse cumulative visibility impacts at both Yellowstone NP and UL 
Bend WA. These adverse impacts from RPP have been repeatedly demonstrated in the many 
modeling analyses presented as part of the ongoing PSD and EIS process. 

The FLM finding of an adverse impact is based upon a demonstration that the current or 
predicted deterioration of air quality will diminish the area's national significance, impair the 
structure and functioning of the area's ecosystem, or impair the quality of the visitor experience 
in the area. Modeling results presented in the RPP PSD application and in the DEIS (based on 
1990 data) show one day exceeding a 10% change in extinction and seven days greater than 5% 
change in visibility extinction at Yellowstone NP. Four days exceed a 5% change in extinction at 
UL Bend WA. Further modeling by RPP and NPS/FWS using 1992 data shows two days at 
Yellowstone NP and four days at UL Bend WA exceeding a 10% change in extinction. Thirteen 
and 16 days exceed 5% change in extinction at Yellowstone NP and UL Bend WA, respectively. 
The results of the cumulative visibility analysis (both 1990 and 1992 data) indicate that the RPP 
would be a significant contributing source to adverse visibility impacts at Yellowstone NP and 
UL Bend WA. The values represented in all analyses (whether RPP-only or cumulative) predict 
impacts that would be perceptible to visitors at Yellowstone NP and UL Bend WA, and would 
violate two of the three adverse impact criteria cited above (i.e., impair the visitor's experience 
and diminish the area's national significance). 

The NPS and FWS have concluded that RPP alone would cause an adverse impact to visibility at 
Yellowstone NP and UL Bend WA, and contribute significantly to a cumulative adverse impact 
on visibility at Yellowstone NP and UL Bend WA. This finding is clearly supported by language 
found in the Clean Air Act, Code of Federal Regulations, the Administrative Rules of Montana, 
and in the enabling legislation that established Yellowstone National Park. Therefore, we ask 
that the MT DEQ not grant a final PSD permit to RPP until our adverse impact concerns are 
adequately addressed. 



« 



-WOHEHIV- 
The Morning Star 



Northern Cheyenne Tribe 
Administration 

P.O. BOX 128 
Lame Deer, Montana 59043 

(406)477-6284 yt 

fax (406)477-6210 



» 



-WOHEHIV- 
The Morning Star 



! (CHIVED 

DEC 1 9 2002 



Montana Department of Environmental Quality 

P.O. Box 200901 

Helena, Montana 59620-0901 



MQ 



Re: Comments on the Draft Environmental Impact Statement for the proposed 
Roundup Power Pjrrjelp 



Dear Mr. Greg Hallsti 



Thank you for the o 



1. 



3. 



Page 3-4, 3 
is locat 




e comments on the Draft EIS: 

if Lame Deer, MT, PMI non-attainment area, 
meRPP." 




Page 4- 
miles do 
data on 



&£n CneyenmPfi^fiJlarmed at the potential 
M0t the cufln^BpFects from the combined 

1;2;3, and -H and II ; devekftnents of coalbed 

'row reserve e tribe bas'Heeniricontact with the NPS and 

er and Sandra i'A. about these \isi&iliry-issurt. The tribe 
feat' up. td'rd te mode current sonxces'bsrcfbne to show the 

effects that impact' tlVfcNpnhem Gheyenne-Resefvaticr: 

TsragrapH numbeS Bid 5: "i cid raija ias- been known to form 



d |£a coal tired povJ^nAant. 1 ; havecvt y_ years of met 



Cheyenne Reservation. The prevailing sands are from the 
west, nortlfiwest as ■uherefcre die reservation should be impacted from RPP. 

Page 4-1 a ; 4.2.1: ParajB|nuiE 
closest federal n on- mandator) t 
Reservatif&i (NCSA. Iocateom30$ffl 

The Northern Cheyenne Air Quality; Division reci:. 

2002. TheMo ie due within one IcfDe 

time lme/foKvig»BBEEIS~ othei; en\ ironmen^fl^prq 

sufficient time to make comments. The environmental staff will need to be 

involved in the formal determination regarding adverse impacts. 




celf read: "The 
Cheyenne 



ecember 12, 
the limited 
not have 




LITTLE WOLF AND MORNING STAR - Out of defeat and exile they led us back 
to Montana and won our Cheyenne homeland that we will keep forever. 



For any question on these comments please contact Jay Littlewolf at 406-477-6506. 
Sincerely, 





Geri Small, President 
Northern Cheyenne Tribe 

cc: Northern Cheyenne Tribal Council 
Dick Long, EPA, Region VIII 
Monica Morales, EPA, Region VIII 
Jay Littlewolf, Air Quality, NCT 



i 
I 




V 

COMMISSIONERS P.O. Box 35000 

(406) 256-2701 Billings, MT 59107-5000 

(406) 256-2777 (FAX) commission@co.yellowstone.mt.us 



December 9, 2002 

RECEIVED 

Mr.GregHallsten DEC 1 2002 

Montana Department of Environmental Quality 

P O Box 200901 m DEPI 0F ENV - QUALfTY 

u i x 7 ♦ cnon noni PERMITTING & COMPLIANCE DM 

Helena, Montana 59620-0901 

Dear Mr. Hallsten: 

The purpose of this letter is to support the construction and operation of the proposed 
700-megawatt coal-fired power plant south of Roundup in Musselshell County. A review 
of the draft EIS would indicate two deficiencies in the study: 1. Lack of full consideration 
for the positive economic impact the project would have to this region. 2. The 
predominate wind direction for this region is from the Southwest. The possible 
decrease in visibility to Yellowstone National Park is misrepresented. 

As a Yellowstone County Commissioner, I ask that you issue the necessary permits 
required forihexonstruction and operation of this much-needed project. 





E. Reno, Commissioner 



Cc: Musselshell County Commissioners 
Joe Gerbase, Attorney 



17 December 2002 

From: Subdivisions and Planning 

Subject: Comments on Roundup Power Project Draft EIS 

To: Montana Department of Environmental Quality 
Attn: Greg Hallsten 
PO Box 200901 
Helena, MT 59620-0901 

Dear Mr Hallsten, 

Overall the draft EIS for the proposed Roundup power plant is good and reaches the 
proper conclusion that the project should go forward and be granted the air quality permit. 
However, the draft understates the county government's ability to provide increased emergency 
services during the construction phase and also understates short-term road impacts. 

It is not my intention to provide bullets for those who oppose this project, but to have the 
document properly recognize that there will be short-term impacts. The following issues should 
be more fully addressed in the EIS and are referenced by paragraph and page numbers: 

1 . Page 3-66, section on taxes: This section should put into perspective the overall 
financial health of the county in relation to the reduction of taxable valuation since 1986. The 
county has been forced to reduce or eliminate many services during this period and this 
significantly affects our ability to provide increased services to these projects during the 
construction phase. Once tax revenues increase, we can deal with these issues appropriately. 
When you couple the impact of the mine construction and power plant construction, we will have 
some significant impacts quickly, and these will be before new revenues begin. Since paragraph 
4.12.1 rightfully acknowledges the perspective of both projects, the rest of the document should 
do so also. 

2. Page 3-75, section on health and safety: The sections on law enforcement and fire 
were not coordinated with the proper department officials, and this affects the conclusions in 



section 4. 12.8 because of incomplete information. The County Sheriff, and County Fire Chief 
who chairs the County Fire Council, were not consulted. 

3. Paragraph 4. 1 . 1 , page 4-1 discusses mitigation that may be required and mitigation 
that may be recommended as a condition for permitting. The draft EIS does not make any 
recommendations for any matter related to emergency services, nor does it discuss who or how 
these services are to be provided. The assumption seems to be that the county can absorb these 
impacts. They are not negligible during the construction phase due to lack of funding, and they 
will be significant to law, fire, ambulance, and roads. If mitigation of these cannot be required, 
they must be stridently sought by us. Understating the short-term impacts does not assist this 
process. 

4. Paragraph 4.12.6, page 4-91. There is no mention of impacts to county and local roads 
during the construction phases of the mine or power plants. 

5. Paragraph 4.12.8, page 4-93. Musselshell County has had and continues to have a 
high crime rate associated with our poor economic conditions. The data used to suggest a low 
crime rate for 1999 was a known aberration due to faulty reporting. A short time prior to 1999 
we had the highest crime rate in the state, and using 1999 data misrepresents our current crime 
statistics. Our current law enforcement department is underfunded and understaffed. Any 
increase in crime will have serious impacts to the department's capabilities and this was 
acknowledged on page 3-75 but not here or the following impact tables on page 4-96. Although 
the County fire department is properly trained and staffed and has significant capabilities, they 
are located a long way from the proposed site. Other area fire agencies are not properly staffed, 
trained, nor equipped to handle any increase in demands for services from new development or 
from the power plant or mine requirements. (There is no discussion in the EIS of how these 
services would be provided at the sites.) The County is in the process of developing a strategic 
fire plan to address the current and future deficiencies and has taken steps to improve services, 
but we recognize our present limitations. On page 3-75, it is recognized that our ambulance 
service is already at the limits of providing services. Section 4.12.8 fails to follow up and make 
any statement about this issue. 

6. Table 4-37: The section on traffic fails to recognize impact to county and local roads 
during construction, before revenues increase. The section on law fails to recognize that any 
increase, particularly during the construction phase, would be a significant adverse impact. The 
section on ambulance is also understated during the construction phase. The impacts would be 
severe for the ambulance service during construction with 800 workers in a high-risk 
environment. The impact to fire services would be moderate to severe permanently. The ability 
of the county fire department to provide structural protection is already limited and any 
additional development will further stress this system. Although the mine operators have stated 
they will handle fire, every major event at either site will involve local government services for 
law, fire, and EMS and we expect this to be so for the power plants. 

7. Paragraph 4.12. 1 1, second section, draws the wrong conclusions as discussed above. 



8. Page 4-106 section on socioeconomic cumulative impacts is again understated as 
discussed above. Providing adequate emergency services to the community and to these projects 
is essential for the success of the projects, and our emergency services community has impacts 
that need more discussion in the EIS. 

9. The consultation section does not list any consultation with local officials. No where 
in the document was Disaster and Emergency Services referenced or consulted. 

10. In the reference section, land use portion, county subdivisions and planning is the 
source for the facts at-a glance document. 

Sincerely, 



Kirby Danielson 
Subdivisions and Planning 



I O 1 

1 53 ' 1 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\> ^ REGION 8 



^^^ 999 18 th STREET - SUITE 300 

DENVER, CO 80202-2466 



Ref: 8P-AR 



Steve Welch, Director 



Phone 800-227-8917 
http://www.epa.gov/region08 



RECEIVED 

DEC | 8 2Q0B DEC 2 2002 

Permitting and Compliance Division m DEPT Qp £w Qu 

Montana Department of Environmental Quality PERMITTING & CQMPLIANPFrw 

P.O. Box 200901 ' ' m 
Helena, Montana 59620-0901 

Dear Mr. Welch: 

I am writing to provide comments on the Preliminary Determination on the Roundup 
Power Project (Permit #3 1 82-00) (draft permit). I understand that you are accepting comments 
on the draft permit through December 18, 2002. We believe there are several issues that should 
be addressed and provisions of the draft permit that should be revised before the permit is issued 
in final form. The enclosure to this letter specifically discusses concerns we have with the draft 
permit. 

With respect to the draft permit our major concerns are with Best Available Control 
Technology (BACT) and Case-By-Case Maximum Available Control Technology (MACT). 
Specifically, we believe that lower BACT levels should be established for S02, NOx and 
particulates and that the Case-By-Case MACT requirements have not been met. The BACT and 
MACT concerns, as well as other concerns with the draft permit, are addressed in the enclosure 
to this letter. We believe the draft permit should be revised to address the enclosed concerns 
before it is issued in final form. 

Please contact me at (303) 3 12-6005 if you have any questions regarding this letter. 

?rely, 




Enclosures 

cc: John Wardell, 8MO 

Geri Small, President, Northern Cheyenne Tribe 
Jay Little Wolf, Air Program Manager, Northern 
Cheyenne Tribe 



^ w Printed on Recycled Paper 



EPA COMMENTS ON DRAFT MONTANA PSD PERMIT 
FOR ROUNDUP POWER PROJECT 

BEST AVAILABLE CONTROL TECHNOLOGY (BACT) 

The comments below pertain to each of the two 390-MW pulverized coal (PC) fired boilers. 

1. Particulate : 

The draft permit specifies 0.015 lb/MMBtu as BACT, based on use of a baghouse. We 
believe 0.012 lb/MMBtu or lower should be specified as BACT. A BACT determination of 
0.012 was recently made by the Wyoming DEQ for the WYGEN2 project, a 500-MW PC-fired 
boiler to be constructed by Black Hills Corporation. Wyoming's determination was based on use 
of a baghouse with membrane-type bags (e.g, Goretex). 

2. Sulfur dioxide : 

a. BACT in terms of lb/MMBtu . The draft permit specifies 0.12 lb/MMBtu (on a 

30-day rolling average) as BACT, based on use of a dry S0 2 scrubber and assuming 94% control 
efficiency and worst-case coal sulfur content (equivalent to 1 .90 lb/MMBtu at the scrubber inlet). 
We believe a much tighter lb/MMBtu limit should be specified as BACT, for the following 
reasons: 

(i) Typical coal sulfur content is much less than worst-case. In its BACT 
analysis, the Montana DEQ apparently accepted the permit applicant's use of worst-case coal 
sulfur content as the basis for the proposed S0 2 emission limit of 0.12 lb/MMBtu, without any 
comparative analysis with available coal at lower sulfur content. (Reference: revised permit 
application to Montana DEQ dated April 11, 2002, page 1.). While use of the worst-case coal 
scenario might be appropriate for establishing a short-term (3 -hour or 24-hour) S02 emission^ 
limit, we consider it inappropriate for establishing a 30-day average emission limit, especially 
considering that coal blending can be used at minimal additional cost (and is routinely used in the 
power plant industry) to eliminate or reduce the effect of coal sulfur 'spikes.' 

Since the Montana DEQ's BACT analysis does not indicate what the typical coal 
sulfur content would be for the Roundup project, we have independently examined coal sulfur 
content data available from various organizations, such as the Wyoming Geologic Survey and the 
Energy Information Administration website ( http://www.eia.doe.gov/cneaf/eIectricity/cq/cq.pdf ). 
From these data, it appears to us that typical coal sulfur content in Montana is probably less than 
half of the worst-case coal sulfur content used by the permit applicant. Based on typical coal 
sulfur content, 94% to 96% scrubber efficiency (see further discussion below) and coal blending, 
we believe an S0 2 emission rate in the range of 0.04 to 0.06 lb/MMBtu could routinely be 
achieved on a 30-day average. 



(ii) Actual S02 emission rates at other power plants . Emissions data on EPA's 
acid rain program website (' www.epa.gov/airmarkets ') for years 2000 through 2001 reveal that 
several PSD-permitted power plant boilers in this region (for example, Bonanza 1, Intermountain 
Power 1 and 2, Rawhide 1, Hunter 3 and Colstrip 3 and 4) routinely achieve below 0.10 
Ib/MMBtu for S0 2 , on a 30-day average. In fact, Bonanza, Intermountain Power and Hunter 3 
routinely achieve below 0.080 lb/MMBtu on a 30-day average, despite the fact that the S0 2 
scrubbers at these boilers were constructed many years ago. 

(iii) BACT determinations for similar projects . BACT determinations by other 
states in this region are further evidence that an emission rate much lower than the 0.12 
lb/MMBtu proposed by Montana DEQ can be achieved. For example, a BACT determination of 
0.10 lb/MMBtu (on a 30-day rolling average) and 96% control efficiency was made by the 
Wyoming DEQ for the WYGEN2 project (based on use of a semi-dry S0 2 scrubber). Also, a 
BACT determination of 0. 1 lb/MMBtu (on a 30-day rolling average) was made by the Utah 
DEQ for Hunter Unit #3, a 495 -MW PC -fired boiler operated by Pacificorp (based on use of a 
wet S0 2 scrubber). Also, a BACT determination of 96% control efficiency was made by the 
State of New Mexico for the Mustang power project. 

(iv) Visibility impacts Severe visibility impacts identified by the Federal Land 
Managers may necessitate a tighter emission limit in lb/MMBtu than would otherwise be 
necessary. 

b. BACT in terms of control efficiency . A minimum required S0 2 scrubber 
efficiency should be included in the permit, to ensure proper operation and maintenance of the 
scrubber, and to ensure that S0 2 emissions are minimized at all times, regardless of the sulfur 
content in the coal. Because of the severe visibility impacts identified by the Federal Land 
Managers, we believe the permit should specify scrubber efficiency in the range of 94% to 96% 
(on a 30-day rolling average), with compliance to be demonstrated via S0 2 CEMS at the scrubber 
inlet and outlet. We note that 40 CFR 60.47a(b)(l) already requires inlet and outlet CEMS. We 
consider 96% efficiency achievable based in part on BACT determinations by other states 
(mentioned above), and on vendor literature from Babcock and Wilcox (a manufacturer of large 
PC-fired boilers and control equipment; see www.babcock.com). which indicates that even 
higher S0 2 control efficiencies of 96% to 98% can be achieved with dry scrubbers, even where 
low-sulfur western coal is used. 

3. Nitrogen oxides . 

The draft permit specifies 0.07 lb/MMBtu (on a 30-day rolling average) as BACT, based 
on combined use of low-NO x burners (LNB), selective catalytic reduction (SCR) at 80% control 
efficiency, and overfire air (OF A). The Montana DEQ's discussion of available control 
technologies for NO x fails to mention ultra-low-NO x -burners (ULNB). Vendor literature from 
Babcock and Wilcox (see www.babcock.com ) indicates that ULNB, in conjunction with 90% 
efficient SCR, could achieve NO x emission rates in the range of 0.015 to 0.025 lb/MMBtu. 



ULNB combined with SCR is currently available. For example, it has been installed at the 
Hawthorn plant in Kansas City. ULNB is important to consider because we believe there are 
potential NO x -related visibility issues with the draft permit for Roundup project (as discussed 
elsewhere in this letter). These issues may necessitate a more stringent NO x emission limitation 
than would otherwise be necessary. Also, we believe SCR can achieve better than 80% control. 
We note that the State of New Mexico made a BACT determination for the Mustang power 
proj ect with a 93% efficient SCR. 

CASE BY-CASE MAXIMUM AVAILABLE CONTROL TECHNOLOGY (MACT) 

The project is subject to case-by-case MACT pursuant to section 1 12(g) of the Clean Air Act. 
However, Montana DEQ did not establish case-by-case MACT limits or follow the procedures 
specified in the Administrative Rules of Montana (ARM) 17.8.342 or 40 CFR §63.43(c) Review 
options, (f) Administrative procedures for review of the Notice of MACT Approval, (g) Notice of 
MACT Approval and (h) Opportunity for public comment on the Notice of MACT Approval. ' 

1 . The draft permit does not contain a case-by-case MACT determination for the Project. 

2. Montana DEQ must issue a Notice of MACT Approval with the initial case-by-case 
MACT determination as described in §63 .43(g). The permit may serve as the Notice of 
MACT Approval or a separate and independent Notice of MACT Approval may be 
issued according to §63. 43(c)(2). 

3 . The minimum public comment period for a Notice of MACT Approval as required by 
§63.43(h)(l)(ii) is 30 

4. The case-by-case MACT determination must contain information specified in §63 .43(g) 
Notice of MACT Approval such as, but not limited to: 

a. MACT emission limitations, 

b. notification, operation and maintenance, performance testing, monitoring, 
reporting and record keeping, 

c. compliance certifications, and 

d. other terms and conditions necessary to ensure Federal enforceability of the 
MACT emission limitation. 

5. The Permit must include all applicable requirements from Part 63 subpart A, as required 
by §63. 43(c)(4). 

6. Construction on the Project is prohibited until Montana DEQ has issued a final and 
effective case-by-case MACT determination as required by §63. 42(c). 



'Although the permit analysis at page 6 indicates that case-by-case MACT applies to the 
main boilers, nowhere does the draft permit specify MACT limits. 



7. The Permit must be revised to include a case-by-case MACT determination in accordance 

with ARM 17.8.342 and 40 CFR part 63, subpart B, §63.40 through 63.44. 

INCREMENT IMPACT AT NORTHERN CHEYENNE INDIAN RESERVATION 
(NCIR) CLASS I AREA 

In the draft EIS, cumulative modeled impacts predict that the 3-hr and 24-hr S02 Class I 
increments are exceeded in the NCIR Class I area (see Table B-2 of the draft EIS). Under our 
stated policies, if the Project's modeled contribution is significant, then it would appear that the 
permit should not be issued without further control or offsets. See 40 CFR 5 1 .1 66(k); pages 
C.52 and C.53 of EPA's October 1990 New Source Review Workshop Manual; EPA's July 5, 
1988 Memorandum from Gerald A. Emison, Director, OAQPS, to Thomas J. Maslany, entitled 
"Air Quality Analysis for Prevention of Significant Deterioration (PSD)." 

Presently, our regulations establish no set values for significance for impacts on Class I 
increment, and to our knowledge, the Montana SIP does not establish values for significance for 
such impacts either. In concluding in the draft EIS that the Roundup Project would not be a 
significant contributor to increment exceedances in the NCIR Class I area, it appears that the 
State has assumed that Class I significance levels EPA proposed in 1996 as part of the NSR 
reforms proposal (published in the Federal Register on July 23, 1996 - 61 FR 38250) are 
appropriate. It would be helpful if you could confirm that this is the approach you are using and 
your basis for concluding that these values represent an appropriate significance threshold for 
evaluating impacts on Class I increment. 

In addition, we note that the modeled values for the Project are just under the significance 
levels for Class I increment used in the draft EIS. Under the circumstances, we believe it is 
important to carefully verify these modeled values and to correct any deficiencies in the 
modeling. For example, it appears that the predicted increment exceedances were based on the 
CALPUFF model being used for all sources near and far to the Class I area. This is not the 
correct regulatory approach for sources near the Class I area. Rather, the correct regulatory 
modeling approach would be to use CALPUFF for sources greater than 50 kilometers from the 
Class I area and ISC for sources less than 50 kilometers from the Class I area. Also, as we 
describe in greater detail elsewhere in this letter, it appears you may have underestimated 
emissions from the auxiliary boilers and other sources in your modeling, and we are unable to 
determine whether modeled values for the main boilers represent worst-case emissions on a 3- 
hour and 24-hour basis. 

Even if issuance of the permit is appropriate without further conditions, the apparent 
Class I increment violation would need to be addressed through reduction of emissions from 
other sources that contribute to the problem. In this regard, 40 CFR 51.166(a)(3) requires a SIP 
to be revised if the State or EPA determines that an applicable increment is being violated. 
Under this regulatory provision, the plan must be revised within 60 days of such a finding by the 



State or notification by EPA, or by such later date as prescribed by the Administrator after 
consultation with the State. 

VISIBILITY 

EPA Region 8 supports the letter of August 27, 2002 from Christine Shaver of the 
National Park Service and Sandra Silva of the US Fish and Wildlife Service to the Montana 
Department of Environmental Quality. This letter outlines the concerns these Federal Land 
Managers (FLMs) have regarding the incremental visibility impacts resulting from the air 
emissions from the Roundup Power Project. The analysis performed by the FLMs demonstrates 
significant impacts from sulfur dioxide and nitrogen oxides on many PSD Class I areas 
surrounding the plant, including Yellowstone National Park, UL Bend Wilderness Area, North 
Absaroka Wilderness, and Northern Cheyenne Indian Reservation (NCIR). 

SHORT-TERM EMISSION LIMITS 

Generally, the PSD regulations require short-term emission limits to ensure protection of 
the applicable national ambient air quality standard (NAAQS) and PSD increments. Specifically, 
the PSD regulations clearly require that the application of B ACT be at least as stringent as any 
applicable standard of performance under 40 CFR Part 60. However, this should not be taken to 
supercede any additional limitations as needed to enable the source to demonstate compliance 
with the NAAQS and PSD increments. See enclosed November 24, 1986 memorandum from 
Gerald A. Emison, Director, Office of Air Quality Planning and Standards, to David Kee, 
Director, Air Management Division, Region V, regarding "Need for Short-term Best Available 
Control Technology (BACT) Analysis for the Proposed William A. Zimmer Power Plant. 

Currently the draft permit only contains S02 emission limitations on a 30-day rolling 
average. This approach may be acceptable only if modeling for protection of the short-term 
NAAQS and PSD increments was based on worst-case hourly S0 2 emissions, rather than on the 
30-day emission limitations in the draft permit. Based on the information we've reviewed, we 
cannot tell whether worst case hourly conditions were modeled. Table 4-8 (page 4-13) of the 
draft EIS indicates that hourly lb/hr limits and annual lb/hr limits were modeled. The document 
does not clearly explain what the hourly lb/hr limits are based on; there are no such limits in the 
draft permit. For example, are these levels based on the source's maximum potential to emit? 

At a minimum, we believe that the permit action should either establish short-term 
emission limits in the permit itself, or justify that worst-case hourly S02 emission limits have 
been modeled for protection of short-term NAAQS and PSD increments. Our preference would 
be that the permit itself include the worst-case modeled hourly S02 emission limits, in addition 
to the 30-day BACT limits. 

Our concern about short-term emission limits does not apply to the particulate matter or 
carbon monoxide emission limits because for these pollutants the draft permit levels are in terms 



of lbs/hr averaged over the period of a stack test (typically about 3 hours), rather than on a 30-day 
rolling average. 

The NOx emission limits in the draft permit are expressed on a rolling 30-day average, 
but we do not see this as an issue for protection of NAAQS and PSD increment, because the 
NOx NAAQS and increment are annual averages. However, we do support the comment that the 
National Park Service made in its August 27, 2002 letter to Dan Walsh, that an equivalent 24-hr 
limit be set for NOx to control short-term impacts upon visibility. 

AUXILIARY BOILERS 

1 . The draft permit only requires a stack test once every five years for NO x and S0 2 emissions 
from the auxiliary boilers. We do not believe this is adequate to demonstrate continuous 
compliance with the emission limitations in lbs/hr. For S02, the permit should also require 
recordkeeping for sulfur content in the fuel oil burned, the quantity of fuel oil burned per hour, 
and the resulting S02 emission rate in lb/hr. For NOx, the permit should require annual stack 
tests, unless test results are sufficiently below the emission limitation that test frequency can be 
reduced to once every five years. 

2. We have several questions with respect to the PM1 0, SOx and NOx emission calculations on 
pages 23 and 24 of the draft permit and the provisions in sections II.A.13 through 17 and 19. 

First, section II.A.16 limits diesel consumption of the two auxiliary boilers to 5,438,400 gallons 
per rolling 12-month period and section II.A.17 limits the combined hours of operation of the 
two auxiliary boilers to 3,300 hours per rolling 12-month period. If you divide total oil 
consumed by total hours of operation (5,438,400/3,300) you would consume 1,648 gal/hr. Yet 
the calculations on pages 23 and 24 assume that 823 gals/hr of oil are used. The calculations on 
pages 23 and 24 of the draft permit and the emission calculations for the auxiliary boilers in 
Appendix B 2 of the permit application seem to imply that the fuel oil consumption for all 
auxiliary boilers will be around 2,766,000 or 2,716,000 gallons year, respectively. We question 
whether the limit in section II.A.16 was developed in error. If not, we question why 823 gal/hr 
was used in calculations on pages 23 and 24. 

Second, the limit in section II.A.13 is not consistent with the calculations on pages 23 and 24 of 
the draft permit. The calculations in the draft permit indicate that emissions will be 64.61 lbs of 
S02/hr, yet section II. A. 1 3 has a limit of 6.46 lbs of S02/hr. It appears that the limit in section 
II.A.13 is incorrect. This potential error impacts the modeling. Table 4-8 on page 4-14 of the 
draft EIS indicates that a limit of 6.47 lbs of S02/hr was used in the modeling for each of the 
auxiliary boilers. The permit application also appears to indicate that 6.47 lbs of S02/hr was 
used in the permit modeling. 



2 We were looking at the revised table dated 3/5/02 that was in Tab 2 of the March 8, 2002 
letter from Nicole Wentz to Dan Walsh. 



Third, the limit in section II. A. 1 9 is not consistent with the calculations on pages 23 and 24 of 
the permit. Section II. A. 19 indicates that the sulfur content of the No. 2 fuel oil used in the 
auxiliary boilers shall not exceed 0.05%, yet the calculations on pages 23 and 24 indicate that the 
sulfur content of the fuel oil is 0.5%. Perry's Chemical Engineer's Handbook indicates that No. 
2 fuel oil contains 0.5% sulfur (see 1984 edition, pages 9-10 to 9-1 1). We question whether the 
limit in section II.A.19 is correct. We also believe that section II.A.19 should be rewritten to 
make it clear that only No. 2 fuel oil or better can be burned in the auxiliary boilers. Finally, we 
note that the permit limit for sulfur content in fuel oil needs to be at least as stringent as the 1 lb 
of sulfur per mmBTU fired limit required by ARM 17.8.322(4). 

MISCELLANEOUS CONCERNS 

1 . The permit should make it clear whether compliance with lb/hr limits for S02 and NOx at the 
PC fired boilers is. to be determined via: (a) periodic stack tests, or (b) a combination of CEMS 
for flow and for pollutant concentration in the stack. EPA recommends (b), especially since the 
CEMS's are required for other purposes anyway. 

2. There is no emission limit for sulfuric acid mist. We believe there should be an emission 
limit for sulfuric acid mist and a compliance monitoring method (EPA Method 8). 

3. Section III.H of the permit indicates that construction must begin within 3 years of permit 
issuance and proceed with due diligence until the project is complete or the permit revoked. We 
believe this is an unreasonably long period of time before construction must begin. BACT could 
change considerably in three years; accordingly, our PSD regulations (40 CFR 52.21(r)(2)) 
provide: 

Approval to construct shall become invalid if construction is not commenced within 18 
months after receipt of such approval, if construction is discontinued for a period of 1 8 
months or more, or if construction is not completed within a reasonable time. The 
Administrator may extend the 1 8-month period upon a satisfactory showing that an 
extension is justified. This provision does not apply to the time period between 
construction of the approved phases of a phased construction project; each phase must 
commence construction within 18 months of the projected and approved commencement 
date. 

Although the Montana SIP does not appear to contain an equivalent provision, it does contain 
ARM 17.8.819, "Control Technology Review," which corresponds to our 40 CFR 51.166(j). 
Subsection (4) of ARM 17.8.819 provides that for phased construction projects, the 
determination of BACT must be reviewed and modified as appropriate "at the latest reasonable 
time which occurs no later than 18 months prior to commencement of construction of each 
independent phase of the project. At such time, the owner or operator of the applicable stationary 
source may be required to demonstrate the adequacy of any previous determination of BACT for 
the source." This makes clear that the maximum length of time a BACT determination should be 



considered valid is 1 8 months, and although the Roundup Project has not been labeled a phased 
construction project, we believe the permit must include a term, consistent with ARM 
17.8.819(4), requiring review of and potential revision to BACT if construction does not begin 
within 18 months. In the alternative, the permit should be revised to require that construction 
begin within 1 8 months. 

4. In Table 5-7 (page 50 of the permit application) and Table 4-38 (page 4-99 of the draft EIS), it 
does not appear that the flare emission limits from the Billings/Laurel sources were considered in 
the NAAQS/MAAQS modeling; the limits shown appear to be only the limits from the 
Billings/Laurel S02 State Implementation Plan (SIP). The flare limits must be considered in the 
NAAQS/MAAQS modeling. 

5. The draft permit does not provide a method for monitoring compliance with the VOC 
emission limit in section II. A. 10. 

6. The draft permit does not indicate how the DEQ determined that the 10 to 12-year-old PM-10 
ambient data represent the year preceding the receipt of the application. We believe the DEQ 
should provide an explanation as to why the data represent the year preceding the receipt of the 
application, or require that ambient PM-10 data be collected that represents such timeframe. 

7. EPA has not approved into the SIP the de minimis permitting provisions mentioned in section 
II.C.2. We believe section II.C.2 should be removed from the permit. 




01 /07/03 1 7 : 40 : 02/03 NO : 274 



Iontana Historical Society 

225 N.>nh Roberts ♦ TO. Box 201201 * Helena, MT 59620-1201 
* (406) 444-2694 ♦ FAX (406) 444-2636 ♦ www.mnnujuhutoricakocicty.oig* 



Thursday, December 12, 2002 

ATTN: Greg Hallsten RECEIVED 

DEO 

POB 200WI DEC 1 » 2002 

Helena MT 59620 

MT EPT. OF ENV. QUALITY 
RE: DEIS Roundup Power Project reMTTINQ i COMPLIANCE DM 

Dor Mr. Hallsten: 

Thank you for providing us a copy of the above referenced document for our review. We 
are able to provide only brief generic comment since we have not received copies of the 
relevant cultural resource report* referenced on page 7-6. 

p.1-7 It » at tWa point incorrect to state that the SHPO it reviewing the project under 
section 106 of the NHPA as no responsible federal agency is identified, SHPO normally 
consults with DEQ or other state agencies under the Montana Antiquities Act and/or 
MEPA. 

p.2-40 Again reference to section 106 of the NHPA is misleading unless this becomes a 
federal undertaking. We agree with generic mitigation of impacts to cultural resources as 
proposed under CR-1 , -2, -3 and 4 (however we find the reference to section 106 
technically misleading). 

p.3-36 Wo have not seen the current cultural resource inventories so we cannot comment 
on the inventory section of this document, or possible effects to particular resources 
whose location and nature is unknown to us, 

p.4-52 Again, since we have not seen the cultural resource reports we are una- j to 
comment other that to agree that areas not inventoried (i.e. groundwater well/pipeline, 
disposal haul road and conveyor routes) may contain important unknown cultural 
resources. 

p.5-3 The correct relationship among the NHPA , MEPA and SHPO is stated here. 

Whether or not we ate requested to provide comment on specific site significance, effects 
or mitigation we believe it would be appropriate that the cultural resource reports 
prepared for this project be submitted to our office for inclusion in the statewide 
inventory, see M.C.A.22-3-423, 



^ 



State Historic Preservation Office * mioh^aw ♦ r»o, n<w 2012^2 *h<<w«, mt 59*211-1202 

(406)444 -771 S * FAX (406)4 <M 6175 



¥ 



01/07/03 17:40 6 1 : 03/03 NO: 274 



We would be more than happy to provide more detailed comment or opinion regarding 
site eligibility, effects or mitigation to DEQ, or the proponent, as desired, once we haw 
the referenced reports. 



Srncnly, 




Stan Wflmoih, PhD. 

State ArchaeoJogiet/Deputy, SHPO 



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