Comments on Colstrip Title V Permit - ClimateWest

We request the DEQ assess this information, as well as information gathered by the EPAand other relevant sources, in order to ensure that the Title V Permit assures the Colstrip powerplant will comply with any applicable NSR requirements and, if necessary, include a complianceschedule to bring the facility into compliance with NSR. In order to ensure compliance withTitle V requirements, it is critical that the DEQ investigate whether NSR requirements have beentriggered and if so, to ensure such requirements are incorporated into the Title V Permit.3. Monitoring ConcernsWe have the following concerns over the monitoring requirements:• Opacity from Coal Handling Systems (EU007, EU008), Coal Piles (EU009), and PlantRoads (EU014): We are concerned that the draft Title V Permit requires insufficientperiodic monitoring to ensure compliance with applicable opacity limits for theseactivities. In particular, although the permit allows the polluter to conduct a weeklyvisual survey of visible emissions from the ash handling operations, coal handlingoperations, the coal piles, and plant roads, it also allows the polluter to simply conduct aMethod 9 source test once every six months and forego any weekly monitoring.Allowing Method 9 testing once every six months does not appear to be sufficientlyfrequent to ensure compliance given that the Title V Permit implicitly indicates thatweekly monitoring of visible emissions is considered to be sufficient periodic monitoring.Above all, it does not appear that monitoring once every six months will assurecompliance with the applicable opacity limits, particularly given that they apply on acontinuous basis.We are further concerned that the monitoring overall simply fails to ensure compliancewith the relevant opacity limits. Technically, the draft Title V Permit does not evenrequire the polluter to monitor for opacity even if visible emissions are observed fromcoal handling, coal piles, and plant roads. It does not appear as if the monitoring set forthis sufficient to ensure that any potential exceedances or violations are detected, recorded,and reported as required.We are finally concerned that it is unclear where any visual surveys of visible emissionsor Method 9 tests would actually occur in relation to the coal handling, coal piles, andplant roads. The Title V Permit does not specify where such monitoring should takeplace in order to assure compliance with the applicable opacity limits.We are also concerned that the draft Title V Permit does not require any monitoring ofopacity or particulate matter from the process ponds. We presume that coal ash isdisposed of within the process ponds, raising concerns over the potential for opacity andparticulate matter emissions. To ensure compliance with the applicable limits, the draftTitle V Permit must ensure monitoring of opacity and particulate matter from the processponds.6

40 C.F.R. § 60.13, which require that CEMS operate continuously except only duringcertain situations. There does not appear to be any authority for allowing the pollutersuch monitor downtime, unless the monitor downtime is only during situations allowedby applicable requirements. Similarly, it appears that Sections II.C.35.h and i aresimilarly inappropriate and contrary to applicable requirements in that they condoneunacceptable monitor downtime for units 3 and 4.Finally, SectionII.C.35.j appears contrary to applicable requirements as well. To beginwith, it does not appear to be written clearly. Secondly, it appears to state that if the TitleV Permit contradicts with applicable requirements, that the Title V Permit applies. If thisis the case, then this provision is contradictory to Title V regulations and must beremoved.• Section II, Condition B.12 is vague and unenforceable as a practical matter. It is unclearhow PPL will maintain and operate the scrubbers to control emissions to actually meetthis requirement. For instance, it is unclear what specific activities PPL must undertaketo maintain the scrubbers, how frequently such maintenance must be conducted, andwhether such maintenance and operation will be sufficient to ensure compliance with PMand other applicable limits.Furthermore, we question why similar scrubber operation and maintenance requirementsare not included for boilers 3 and 4. It would appear that given that venturi scrubbers areutilized for these boilers that the Title V Permit should include requirements that ensurethese control devices are properly operated.• The draft Title V Permit indicates that the greenhouse gas reporting requirements under40 C.F.R. § 98 are “NOT an applicable requirements under Title V.” Draft Title VPermit at 6. It is unclear how the DEQ concluded that these requirements are notapplicable under Title V. The permit either needs to be revised to ensure that theseapplicable requirements are fully incorporated and enforced, or explain why it believesthe greenhouse gas reporting requirements are not applicable.Thank you for the opportunity to comment.Sincerely,Jeremy NicholsClimate and Energy Program DirectorWildEarth Guardians1536 Wynkoop, Suite 301Denver, CO 80202(303) 573-4898 x 1303cc: EPA Region 89