Comment on FR Doc # E9-23633

Document ID: EPA-R09-OAR-2009-0598-0220
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: October 26 2009, at 12:00 AM Eastern Daylight Time
Date Posted: April 5 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: September 30 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: October 28 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 80a4bd28
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This is comment on Proposed Rule

Assessment of Anticipated Visibility Improvements at Surrounding Class I Areas and Cost Effectiveness of Best Available Retrofit Technology: Four Corners Power Plant and Navajo Generating Station

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Our comment is the following: It is inappropriate to treat HCl and HF as PM Fine for BART Modeling HCl and HF are emitted as gases and will not form particles that impact visibility on a regional level. Treating HCl and HF as non-volatile PM Fine mass is incorrect. In the attached document (attached in 2 parts), we review the physical properties of HCl and HF in detail, and also use theoretical calculations and measurement data to demonstrate that treating these components as PM Fine or H2SO4 is inappropriate for regional haze calculations.

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Comment on FR Doc # E9-23633

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Comment on FR Doc # E9-23633

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Comment on FR Doc # E9-23633 (2)

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Comment on FR Doc # E9-23633 (2)

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Total: 16

Comment on FR Doc # E9-23633
Public Submission Posted: 04/05/2010 ID: EPA-R09-OAR-2009-0598-0217