James A.

Mennell
The Environmental Law Group
East Bridge at Riverplace, Suite 114
10 Second Street Northeast
Minneapolis, Minnesota 55413
Dear Mr. Mennell:
I am in receipt of your letter from June 26, 2006, which you sent to Mr. Gregory Fried in
my division. On behalf of Great River Energy (GRE), you requested reconsideration of a letter
which I issued to GRE on February 8, 2006, regarding the applicability of the proposed New
Source Performance Standard (NSPS) for New Stationary Combustion Turbines (40 CFR
Part 60, Subpart KKKK). In that letter, the United States Environmental Protection Agency
(EPA or the Agency) determined that NSPS Subpart KKKK would be applicable to the
combustion turbine at GRE=s Cambridge, Minnesota facility.
Although your letter provides a more detailed statement of your contention that
Subpart KKKK is not applicable to the stationary combustion turbine at GRE, it does not provide
any new information that would cause the Agency to reconsider the February 2006, applicability
determination. Furthermore, the final regulations for NSPS Subpart KKKK, which were
promulgated on July 6, 2006 (after the February 2006, determination) did not change the
applicability criteria in any way that would alter the response. For these reasons, the Agency is
declining to reconsider its February 2006, determination.
This response has been coordinated with appropriate offices within the Agency. The
current contact on my staff for stationary combustion turbines is Sally Harmon. You may reach
her at (202) 564-7012.
Very truly yours,

Michael S. Alushin, Director

Compliance Assessment and Media Programs Division
Office of Compliance
Preparedby:s.harmon:mlw:10-10-07:564-7012:2223A:GRE.Response for Reconsid-final[rev1010-07]doc.doc

2
bcc:

Christian Fellner, Office of Air Quality Planning and Standards

Rick Vetter, Office of General Counsel
Scott Jordan, Office of General Counsel
Elliott Zenick, Office of General Counsel
Mamie Miller, Office of Compliance
Gregory Fried, Office of Civil Enforcement
Kevin Vuilleumier, EPA Region 5