Memo to the Docket
Docket  -  EPA-R08-OAR-2012-0026

We had a meeting with PacifiCorp on October 31, 2013 with Cathy Woolhums, Bill Lawson, Chad Teply, and Mike Jenkins representing PacifiCorp.  
Representing EPA were Carl Daly, Laurel Dygowski, Aaron Worstell, Monica Morales, Steve Odendahl and Paul Logan.
The following are the questions EPA posed to PacifiCorp and a summary response.
We have reviewed PacifiCorp's August 26, 2013 comments and have the following clarifying questions.
   1) For Naughton Unit 3, PacifiCorp has a comment on page 72 pertaining to the conversion of natural gas.  Does this comment indicate that PacifiCorp wants EPA to finalize as part of its FIP the requirement for PacifiCorp to convert the unit to natural gas with a NOx emission limit of 0.08 lb/MMBtu, which would be in lieu of finalizing our proposed approval of an emission limit of 0.07 lb/MMBtu (which was based on SCR)? 
   Answer: Yes.
   2) In addition, EPA would need to include emission limits for SO2 and PM in its FIP.  An emission limit for SO2 is required to show that the visibility benefits of natural gas conversion are superior to those from SCR.  A PM emission limit is required under BART.  If EPA included a PM emission limit of 0.008 (30-day rolling average) (this limit is derived from the State's permit) in its FIP for Naughton Unit 3, and if EPA included an emission limit of 0.0006 lb/MMBtu (30-day rolling average) (this limit is derived from the State's permit) for SO2 in its FIP, would PacifiCorp have an objection to either limit?  
   Answer: PacifiCorp would not object to either limit being included.
   3) For Naughton Unit 1 and 2 and Dave Johnston Unit 3, PacifiCorp indicates in its comments on page 37, that it plans on shutting down the units in 2029 and 2027, respectively.  Should we interpret PacifiCorp's comment to say that it is requesting that EPA include these shut-down dates as federally enforceable requirements in our FIP in lieu of a potential FIP requirement for SCR?
   Answer: Yes, PacifiCorp would want those dates included in lieu of a requirement for SCR.
   4) Would PacifiCorp still plan on shutting down Naughton Units 1 and 2 in 2029 and Dave Johnston Unit 3 in 2027 if EPA did not propose to require SCR on these units for BART?
   Answer:  It would depend on PacifiCorp's economic analysis and EPA's final action.
   5) Also for Naughton Unit 1 and 2 and Dave Johnston Unit 3, PacifiCorp mentions in its comments on page 2 that they would either shut-down these units or convert them to natural gas. Can you please clarify this statement? 
   Answer:  It would depend on PacifiCorp's economic analysis and EPA's final action.
   
