EPRI Comments on Proposed Rulemaking for Visibility Improvements
EPRI has provided public comments to the U.S. Environmental Protection Agency (EPA) on the Advanced Notice of Proposed Rulemaking regarding anticipated visibility improvements at Class I Areas and cost-effectiveness of Best Available Retrofit Technology (BART) for two generating stations in the Southwest.  EPRI’s comments focus on the scientific appropriateness of EPA’s proposed treatment of hydrogen chloride (HCl) and hydrogen fluoride (HF) as nonvolatile PM fine mass.  Research indicates that HCl and HF are emitted as gases and will not form particles that impact visibility on a regional level.  EPRI ‘s comments review the physical properties of HCl and HF in detail and use theoretical calculations along with measurement data to demonstrate that the treatment of these two emissions as PM fine mass is inappropriate for regional haze calculations.  For more information, contact Eladio Knipping, (202) 293-2691, eknippin@epri.com.