Comment submitted by James L. Kavanaugh, Director, Air Pollution Control Program, Missouri Department of Natural Resources

EPA Docket Center Environmental Protection Agency Mail code: 6102T 1200 Pennsylvania Avenue, Northwest Washington, DC 20460 Attention: Docket ID No. EPA-HQ-OAR-2005-0132 The purpose of this letter is to provide comments on the following Federal Register action: Revisions to the Continuous Emissions Monitoring Rule for the Acid Rain Program, NOx Budget Trading Program, the Clean Air Interstate Rule, and the Clean Air Mercury Rule. (Federal Register, August 22, 2006, Volume 71, Number 162, Proposed Rules, Pages 49253-49308.) The department?s Air Pollution Control Program supports the U.S. Environmental Protection Agency?s (EPA) proposed language relating to default emission rates for fuel oil combustion, in lieu of using the ?generic? default sulfur dioxide (SO2) emission rates specified in Table LM-1 of ?75.19. However, the department encourages EPA to look at additional changes to the provisions of ?75.19. The inclusion of low mass emitting (LME) units, in the Clean Air Interstate Rule will create a financial hardship for many units qualifying as LME units under ?75.19 in Missouri. EPA could eliminate some of this hardship by allowing additional methods for determining the emission rate from LME units for SO2 and nitrogen oxides (NOx). One method would be to use all of the emission factors developed through other federal testing or monitoring requirements, such as 40 CFR 60 Subpart GG. Using these emission factors rather than the ?generic emission factor? would more closely estimate the emissions from an LME unit. The greatest cost of compliance to the LME units is creating a ?site specific emission factor?. The testing cost and the cost of fuel for testing make this option financially difficult for small installations. By allowing these installations to use testing already conducted or is currently required as a result of other EPA regulations, EPA would greatly reduce the burden of Part 75 monitoring requirements on low emitting or low run hour units. One example of the benefit from allowing facilities to use other federally approved tests is the City of Higginsville, MO. Under the current regulations, the LME ?generic emission factor? for NOx is approximately six times higher than the Subpart GG emission factor that was developed through federally approved test methods. Therefore, the company will be forced to purchase six EPA Docket Center Page Two times the number of allocations needed or they will be required to test and develop an emission factor. The test will cost the City of Higginsville over $100,000 and will result in no additional NOx reductions. Actually, the NOx emissions during the test will increase the annual NOx emissions significantly due to the typically low number of hours of operation. By allowing the city the use of Subpart GG factors, the same NOx emissions will result as would typically be expected. This same scenario can be given for several municipal units in Missouri as well as several privately owned units. In summary, the department?s Air Pollution Control Program supports EPA?s currently proposed default emission rate and would request that EPA look at expanding this language to include emission factors that have been developed using federally approved test methods. The department?s Air Pollution Control Program believes the LME unit factors are sufficiently conservative given the low level of emissions that result from these units. The department?s Air Pollution Control Program appreciates the opportunity to comment on this Federal Register action. Should EPA require further information on this matter, please contact the department?s Air Pollution Control Program, Operations Section, at P.O. Box 176, Jefferson City, MO 65102-0176, or by telephone at (573) 751-4817. Sincerely, AIR POLLUTION CONTROL PROGRAM James L. Kavanaugh Director JLK:abr