UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

Mr. Lance R. LeFleur 

Director 

Alabama Department of 

Environmental Management 

P.O. Box 301463 

Montgomery, Alabama 36130-1463 

Dear Mr. LeFleur: 

ATLANTA FEDERAL CENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303-8960 

APR 1 0 2015 

I am writing to update you on the status of the Greene County Electric Generating Plant located in 

Greene County, Alabama, in relation to the U.S. Environmental Protection Agency's efforts to 

implement the primary National Ambient Air Quality Standard (NAAQS) for sulfur dioxide (S02) set in 

2010 at 75 parts per billion (ppb) as a 1-hour average. On March 20, 2015, the Acting Assistant 

Administrator informed you that the U.S. District Court for the Northern District of California accepted 

as an enforceable order an agreement between the EPA and Sierra Club and Natural Resources Defense 

Council to resolve litigation concerning the deadline for completing the remainder of designations for 

the 2010 S02 standard. The court's order directs the EPA to complete designations in three additional 

rounds: the first round by July 2, 2016; the second round by December 31, 2017; and the final round by 

December 31, 2020. In the first round of designations, the EPA will designate two groups of areas: 1) 

areas that have newly monitored violations of the 2010 S02 standard; and 2) areas that contain any 

stationary source that according to the EPA's Air Market's Database either emitted more than 16,000 

tons of S02 in 2010 or emitted more than 2,600 tons of S02 and had an emission rate of at least 0.45lbs 

SO:Ymillion metric British thermal units (mmbtu) in 2012 and that has not been announced for 

retirement (as of March 2, 2015). 

In the EPA's March 20, 2015, letter to you, we named the Greene County Electric Generating Plant as 

meeting the emissions-based criteria established in the court's order. Specifically, the plant was 

identified as emitting 32,461 tons of S02 in 2012 with an emissions rate of 2.678lbs SO:Ymmbtu. The 

EPA has since received additional information from your staff supporting the fact that the facility meets 

the "announced for retirement" criteria established in the court's order, i.e., announced for retirement 

means any stationary source in the United States with a coal-fired unit that as of January 1, 2010, had a 

capacity of over 5 megawatts and that has been announced as of March 2, 2015, that it will cease 

burning coal at that unit through a company public announcement, public utilities commission filing, 

consent decree, public legal settlement, fmal state or federal permit filing or other similar means of 

communication. 

After evaluating the supplemental information that your staff has provided, the EPA agrees that the 

court's order does not direct the EPA to designate the area surrounding Greene County Electric 

Generating Plant by July 2, 2016. As a result, there are no sources in your state meeting the criteria 

established in the court's order for the round of designations that the EPA will complete by that date. 

Internet Address (URL) • http://www.epa.gov 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
The remainder of this letter provides information and resources that may be of use throughout the 

entirety of the designations process, including the rounds of designations that the court has ordered the 

EPA to complete by December 31,2017, and December 31,2020. The designations to be completed by 

December 31, 2017, would address areas where states have not installed and begun operating a new S02 

monitoring network meeting the EPA's specifications referenced in our proposed rule titled, "Data 

Requirements Rule for the 1-hour S02 primary NAAQS." This rule, which was proposed in the Federal 

Register on May 13, 2014, would direct state and tribal air agencies to provide data to characterize 

current air quality in areas with large sources of S02 if such areas do not have sufficient air quality 

monitoring in place to identify maximum S02 concentrations. The additional modeling and monitoring 

data collected by the EPA as a result of this proposed rule, once promulgated and implemented, would 

be used in the designations process both for the 2017 and 2020 deadlines. To guide these remaining 

designations, the EPA has updated its March 24, 2011, designation guidance for the 2010 S02 standard 

to support analysis of designations and boundaries for these next rounds of designations. The EPA has 

also provided two technical assistance documents that provide advice on the use of modeling and 

monitoring data when determining if an area is meeting or not meeting the 2010 S02 standard. Each of 

these three documents can be found on the EPA's website at 

http://epa.gov/airquality/sulfurdioxide/implement.html. The EPA will provide states with additional 

information on the designations process associated with these later deadlines at a later date. 

We look forward to continued dialogue with you and your staff as we work together to implement the 

2010 S02 standard and achieve its intended public health protection. For additional information 

regarding designations for the 2010 S02 standard, please visit our website at 

www.epa.gov/so2designations. Should you have any questions, please do not hesitate to call me or 

Beverly Banister of my staff at 404-562-9326 and banister.beverly@epa.gov. 

Enclosure 

cc: Ronald W. Gore, Chief 

Air Division, ADEM 

Jonathan Stanton, Director 

Jefferson County Department of Health 

Daniel E. Shea, Director 

s~~4J ~Heather McTeer Toney '1' -Regional Administrator 

Division of Natural Resources, City of Huntsville 
ENCLOSURE 

TIMELINE FOR 2010 PRIMARY SOz NAAQS DESIGNATION PROCESS FOR AREAS 

ASSOCIATED WITH JULY 2, 2016, COURT-ORDERED DEADLINE* 

Milestone Date** 

Court Order March 2, 2015 

Impacted states [and tribes] may submit No later than September 18,2015 

updated recommendations and supporting 

information for area designations to the EPA 

The EPA notifies impacted states [and tribes] o/a January 22, 2016, but absolutely no later 

concerning any intended modifications to than 120 days prior to fmal designations, i.e., 

their recommendations (120-day letters) March 2, 2016 

The EPA publishes public notice of state o/a February 3, 2016 

recommendations and the EPA's intended 

modifications and initiates 30-day public 

comment period 

End of 30-day public comment period o/a March 4, 2016 

Impacted states [and tribes] provide additional o/a April 8, 2016 

information to demonstrate why an EPA 

modification is inappropriate 

The EPA promulgates final SOz area No later than July 2, 2016 

designations (no later than 16 months from 

Court Order) 

*The court's order also directs the EPA to promulgate additional rounds of designations by December 

31, 2017, and by December 31, 2020. 

** o/a =on or about