# Appendix N

Hearing Report, Comments Received

and ResponsesHearing Report, Commen ts Received & Responses Appendix N - i

Regional Haze SIP for NC Class I Areas December 17, 2007iii 

### EXECUTIVE SUMMARY

Two public hearings were held for the “Pre-Hearing Draft Regional Haze State Implementation

Plan for North Carolina Class I Areas” and best available retrofit technology (BART)

determinations for Blue Ridge Paper Products and PCS Phosphate Company. The first was held

on November 13, 2007, at the Asheville-Buncombe Technical Community College Main

Campus located at 340 Victoria Road, Asheville, North Carolina. The second hearing was held

on November 15, 2007, at the Department of Environment and Natural Resource Washington

Regional Office located at 943 Washington Square Mall, Washington, North Carolina. The

purpose of these hearings was to inform interested parties on the regional haze State

Implementation Plan including BART determinations and the intent to issue related air quality

permits, as well as to solicit comments from the public. The public comment period closed

November 26, 2007.

According to the Public Hearing Registration Forms, a total of two (2) non-North Carolina

Division of Air Quality (NCDAQ) people attende d the Public Hearing in Asheville, North

Carolina and one (1) person registered to speak. At the Public Hearing in Washington, North

Carolina, a total of three (3) non-NCDAQ people attended the hearing and two (2) people

registered to speak. Written comments were r eceived from the Blue Ridge Paper Products, PCS

Phosphate Company, North Carolina Division of Fo rest Resources, Southeast Visibility Industry

Coalition, Manufacturers and Chemical Industry Council of North Carolina, and the United

States Environmental Protection Agency.

It is our opinion that the NCDAQ can adequately address the concerns raised by the interested

parties. Based on the information contained in this report, we recommend the following:

We recommend that the “Regional Haze State Implementation Plan for the North Carolina Class

I Areas” and the BART determinations and the related air quality permits be approved to move

forward after addressing the hearing officers’ recommendations as described in the body of this

report.iii1 

## Hearing Officer’s Report

for

Regional Haze State Implementation Plan for

North Carolina Class I Areas and

Best Available Retrofit Technology Determinations

and Related Air Quality Permits

December 14, 2007

Robert Fisher and Paul Muller

Two public hearings were held for the “Pre-Hearing Draft Regional Haze State Implementation

Plan for North Carolina Class I Areas” and best available retrofit technology (BART)

determinations for Blue Ridge Paper Products and PCS Phosphate Company. The first was held

on November 13, 2007, at the Asheville-Buncombe Technical Community College Main

Campus located at 340 Victoria Road, Asheville, North Carolina. The second hearing was held

on November 15, 2007, at the Department of Environment and Natural Resource Washington

Regional Office located at 943 Washington Square Mall, Washington, North Carolina. The

purpose of these hearings was to inform interested parties on the regional haze State

Implementation Plan (SIP) including BART determinations and the intent to issue related air

quality permits, as well as to solicit comments from the public. The public comment period

closed November 26, 2007.

Background (borrowed from the draft plan)

The United States Environmental Protection Agency (USEPA) promulgated the regional haze

rule in July 1999, which revised the existing visibility regulations in order to integrate provisions

addressing regional haze impairment and establish a comprehensive visibility protection program

for Federal Class I areas. States are required to submit SIPs to the USEPA that set out each

states’ plan for complying with the regional haze rule, including consultation and coordination

with other states and with Federal Land Managers (FLMs). Additionally, the rule requires states

to assess sources that may be subject to BART controls. The SIPs for the first review period will

cover long-term strategies for visibility improvement between baseline conditions in 2000-2004

and 2018.

There are significant control programs being implemented between the baseline period and 2018.

These programs will all reduce the particulate precursor emissions that affect visibility in the

Class I areas, and include: the Clean Air Interstate Rule (CAIR), the NO

x 

### SIP Call, the North

Carolina Clean Smokestacks Act, consent agreements with Tampa Electric, Virginia Electric and

Power Company, and Gulf Power, one-hour ozone SIPs submitted by Atlanta, Birmingham, and

Northern Kentucky, NOx RACT in 8-hour nonatta inment area SIPs, heavy duty diesel (2007)

engine standard (for on-road trucks and buses), Tier 2 tailpipe standards for on-road vehicles,

large spark ignition and recreational vehicle rule, nonroad diesel rule, and various Federal

Maximum Achievable Control Technology regulations.2 

### North Carolina has five Class I areas within its borders: Great Smoky Mountains National Park,

Joyce Kilmer-Slickrock Wilderness Area, Linville Gorge Wilderness Area, Shining Rock

Wilderness Area, and Swanquarter Wildlife Refuge. The regional haze SIP for North Carolina

Class I areas establishes reasonable progress goals for these five Class I areas for 2018.

Summary of Public Hearing and Comment Period

According to the Public Hearing Registration Forms, a total of two (2) non-North Carolina

Division of Air Quality (NCDAQ) people attende d the Public Hearing in Asheville, North

Carolina and one (1) person registered to speak. At the Public Hearing in Washington, North

Carolina, a total of three (3) non-NCDAQ people attended the hearing and two (2) people

registered to speak.

The public hearing comment period was open until November 26, 2007. Three people spoke at

the public hearings: Paul Dickens, Manager of Environmental Affairs for Blue Ridge Paper

Products, Inc.; Gary Curcio, Fire Environment Forester for NCDFR; and Ross Smith, Manager

of Environmental Affairs for PCS Phosphate Company. Both Mr. Dickens and Mr. Smith

provided written versions of their comments at the hearing. During the public comment period

the Hearing Officer did not receive any phone calls related to the public hearing.

In addition to the comments provided at the public hearings, written comments were received

from Paul Dickens, Manager of Environmental Affair for Blue Ridge Paper Products, Wib L.

Owen Director for North Carolina Division of Forest Resources (NCDFR), John R. Cline,

Counsel to the Southeast Visibility Industry Coalition (SEVIC), A. Preston Howard, Jr.,

President for Manufacturers and Chemical Indus try Council of North Carolina (MCIC), and Kay

T. Prince, Chief Air Planning Branch for the USEPA. The written comments submitted as part

of the public hearing process are attached for reference.

The following is a summary of the pertinent comments, with regards to NCDAQ’s jurisdiction,

raised by all parties involved in the public hearing process along with the Hearing Officer’s

opinions and recommendations.

Blue Ridge Paper Products: In general, the comments received from Blue Ridge Paper

Products stated that they were in agreement with the conclusions drawn in the regional haze SIP.

Only two statements warrant discussion in the hearing record. First, Blue Ridge Paper Products

is a member of SEVIC and requests that the NCDAQ consider the comments submitted on

behalf of SEVIC. Second, the company wished to place into public record facts about their use

of coal and energy use.

Hearing Officers’ Response: The Hearing Officers’ recommendation is that the NCDAQ shall

consider all comments submitted as part of the public hearing process. With the inclusion of

Blue Ridge Paper Products written comments as part of the Hearing Report, the facts about their

use of coal and energy use are placed into public record.

NCDFR: A number of the comments submitted by the NCDFR were suggested changes to

wording within the SIP narrative and in Appendix H.3 

### Hearing Officers’ Response: The Hearing Officers’ recommendation is that the NCDAQ shall

consider all suggested edit changes to the Regional Haze SIP and make changes when the

NCDAQ deems it appropriate.

NCDFR: The NCDFR discussed the importance of developing a fires database.

Hearing Officers’ Response: Since this is not relevant to this SIP package no response is

needed.

NCDFR: The NCDFR discussed the importance of maintaining flexibility to modify the North

Carolina Smoke Management Program (NCSMP) on an as-needed basis without going through a

SIP revision and voiced its concern about certifying a smoke management program.

Hearing Officers’ Response: The NCDAQ does not plan to submit the NCSMP as part of the

Regional Haze SIP. Therefore, changes to the NCSMP will maintain the flexibility to modify

without going through a SIP revision process. With respect to certifying the NCSMP, the need

for this has more to do with the fine particulate matter National Ambient Air Quality Standards

than for regional haze. Therefore, it is the r ecommendation of the Hearing Officers that the two

agencies should discuss this further.

PCS Phosphate Company and MCIC : PCS Phosphate Company and MCIC requested that the

NCDAQ include language in the SIP to make it clear that the reasonable further progress

evaluations do consider the uniform rate of progress in setting the reasonable progress goals for

Class I areas in North Carolina.

Hearing Officer’s Response: In Section 51.308(d)(1)(i) of the regional haze rule states “In

establishing a reasonable progress goal for any mandatory Class I Federal area within the

State, the State must: (A) Consider the costs of compliance, the time necessary for compliance,

the energy and non-air quality environmental impacts of compliance, and the remaining useful

life of any potentially affected sources, and include a demonstration showing how these factors

were taken into consideration in selecting the goal. (B)... ... ... In establishing the reasonable

progress goal, the State must consider the uniform rate of improvement in visibility and the

emissions reduction measures needed to achieve it for the period covered by the implementation

plan.” It is the understanding of the NCDAQ that the State must and did consider all reasonable

measures, taking into consideration the factors in 51.308(d)(1)(i)(A), as well as the uniform rate

of improvement when setting the reasonable progress goals. The USEPA has told states that

even though modeling of current Federal and State programs may demonstrate reasonable

progress goals below the uniform rate of progress, the states still must address if there are other

reasonable measures that will contribute significantly to the improvement of visibility. The

Regional Haze SIP addresses both aspects of 51.308(d)(1)(i) in setting the reasonable progress

goals in North Carolina; it establishes the uniform rate of progress for each of the Class I areas in

North Carolina and it assesses if there are additional reasonable measures beyond the other

requirements of the Clean Air Act. The NCDAQ disagrees with the commenter if he is

suggesting that if the State is meeting the uniform rate of progress then no other analysis is

required. Therefore, it is the recommendation of the Hearing Officers that no further action is4 

### required since the Regional Haze SIP already takes into consideration the uniform rate of

progress in setting the reasonable progress goals for North Carolina’s Class I areas.

SEVIC: A number of the comments submitted by SEVIC were suggested changes to wording or

requesting further clarification within the SIP narrative and related Appendices.

Hearing Officers’ Response: The Hearing Officers’ recommendation is that the NCDAQ shall

consider all suggested edit changes to the Regional Haze SIP and make changes when the

NCDAQ deems it appropriate.

SEVIC: SEVIC commented that it questions whether revised modeling results and reasonable

progress goals could be incorporated in the final SIP without going through a public comment

period.

Hearing Officers’ Response: The Hearing Officers have been informed that the revised

modeling results will not be incorporated in the final Regional Haze SIP since it has come too

late in the process. These results will be addressed in the first periodic progress report (in 2012)

that will be taken through the SIP process. However, the NCDAQ believes that the revised

modeling results could have been incorporated in the final SIP if the results were not

significantly different than what was taken through the public comment process.

SEVIC: SEVIC requests the NCDAQ to commit to account for international emissions during

any required revisions of it regional haze SIP a nd during any periodic review of the progress

towards the reasonable progress goals of the State’s Class I areas.

Hearing Officers’ Response: The Hearing Officers do not think it is prudent to dictate at this

time if international emissions should be accounted for in future Regional Haze SIPs. It is the

recommendation of the Hearing Officers that the NCDAQ should assess if international

emissions should be accounted for in setting the reasonable progress goals for future assessment

periods at the time those goals are established.

SEVIC: SEVIC requests the NCDAQ to comment on the degree of uncertainty in its

determinations of the relative contributions of di fferent pollutants from different States/regions

from the 2009 sensitivity modeling runs.

Hearing Officers’ Response: The intent of using the sensitivity modeling results was not to

determine what the relative contribution from different States/regions had on visibility, but rather

to better understand how reductions in various source sectors would impact visibility. The

NCDAQ used data from existing modeling as a qualitative guide to identify the key pollutants

contributing to visibility impairment at each Class I area. Therefore, it is the recommendation of

the Hearing Officers that the degree of uncertainty is not needed.

SEVIC: SEVIC raised concerns that the sensitivities the NCDAQ used to determine emission

reduction responses did not include days that were influenced by fires.5 

### Hearing Officers’ Response: It is correct that the emission reduction response sensitivities

were based on limited episodes and those episodes contained very few days where fires played a

role in visibility impairment. However, Appendix B contains bar charts that depict the chemical

speciation for the 20% worst days in the base time period of 2000 to 2004 at each of Class 1

areas in North Carolina. It is clear from these graphics that the number of days where fires

played a role in visibility impairment was approximately 2% to 3 % of the days in the entire

baseline period. The remaining days were dominated by sulfate. Therefore, although the

emission reduction sensitivities did not include many days influenced by fires, this should not

impact the ultimate results of the sensitivities. It is the recommendation of the Hearing Officers

that the NCDAQ should provide a better explanation as to why the emissions sensitivities are

appropriate.

SEVIC: SEVIC raised concerns about the sulfate extinction weighted area of influence plots

developed using emissions from 2002 instead of 2018 emissions. SEVIC requested an

explanation of what the differences in area of influence would have been if 2018 emissions had

been used. Finally, SEVIC raised the concerns that the sulfate portion of the weighting is

heavily influenced by sulfur dioxide emissions, which will not be present in 2018.

Hearing Officers’ Response: The area of influence plots were developed to understand the area

that most likely impacted the Class I areas during the baseline period of 2000 – 2004. This

provided the State with a starting point to identif y those sources located within the region that

may have impacted the 20% worst days. The NCDAQ could then evaluate those sources, their

estimated future emissions and any potential control technologies that may be considered

reasonable measures. Although the sulfate extinction weighted residence times were calculated

from 2002 emissions, the only emission sources that decreased significantly between 2002 and

2018 were the electric generating units (EGUs) that are expected to be controlled by 2018. Since

the NCDAQ determined that the North Carolina Clean Smokestacks Act and the Clean Air

Interstate Rule were deemed reasonable control measures for the EGUs, only the non-EGU

sources were left to evaluate. If a non-EGU source happened to be located within the same grid

cell as an EGU, it potentially could have been weighted higher than if it had not. However, since

the NCDAQ evaluated each source on its own merits, the outcome would not have been

different. Therefore, it is the recommendation of the Hearing Officers that the NCDAQ should

provide some additional explanation in the Regional Haze SIP that addresses this issue.

SEVIC: SEVIC stated that they did not believe that the NCDAQ had adequately addressed the

four statutory factors in its analysis of sources identified as potentially contributing to visibility

impairment in the Class I areas. SEVIC reque sted that the NCDAQ provide a fully developed

explanation of all factors for each source and identify what the NCDAQ will be looking at in

future Regional Haze SIPs. SEVIC provided detailed comments on what they believed the

NCDAQ should provide in these analyses.

Hearing Officers’ Response: In addressing the four-factor analysis, the NCDAQ used the cost

of compliance as a screening tool to determine th e universe of sources to perform the four-factor

evaluation. Therefore, this is the area where th e NCDAQ put most of its effort. Had reasonable

cost effective control measures been identified for a source, then a more in-depth discussion

would have been provided on the remaining factors. Had a source been identified that could be6 

### reasonably expected to meet all four factors, then the NCDAQ would have performed modeling

to determine if controls at the source would have improved visibility at any Class I area. It is the

opinion of the Hearing Officers that the NC DAQ should not place limiting factors in this

Regional Haze SIP that may result in issues for future Regional Haze assessments. It cannot be

known at this time what may be needed in future SIPs to address meeting reasonable progress.

Therefore, it is the Hearing Officers recommendation that the SIP as written is adequate for

purposes of the 2018 reasonable progress goals.

SEVIC: SEVIC emphasized the need for this SIP to address 1) more details about what criteria

are part of the overall reasonable progress assessment, 2) which criteria were key considerations

for this planning period, and 3) what changes in those criteria that NCDAQ might speculate at

this time.

Hearing Officers’ Response: The NCDAQ adequately addressed items 1 and 2 in Appendix H

of the Regional Haze SIP and summarized in the SIP narrative. Furthermore, it would not be

prudent for the NCDAQ to speculate at this time what may be important in the future until the

agency has the opportunity to understand how the reduction in sulfur dioxide emissions from the

EGUs will impact the visibility at the Class I areas. The technical assessment and the SIP

documentation for all future Regional Haze SIPs will undergo the same stakeholder involvement

and public review as the current Regional Haze SIP. The NCDAQ expects that stakeholders will

have ample opportunity to provide input on the criteria used for assessing reasonable progress.

SEVIC: SEVIC raised questions regarding the NCSMP. SEVIC wanted to know if the NCSMP

would be submitted with the SIP, will it under go public review and comment, and will it address

agricultural management as well as forestry.

Hearing Officers’ Response: As stated earlier, the NCDAQ does not plan to submit the

NCSMP as part of the regional haze SIP. At this time the NCSMP does not cover agricultural

management, therefore the Hear Officers r ecommend that the NCDAQ include a discussion

about how agricultural management will be addressed.

SEVIC: SEVIC asked if the NCDAQ planned to include the benefits from the new fugitive dust

rule and the North Carolina Department of Transportation’s (NCDOT’s) dust ordinance in the

final Regional Haze SIP.

Hearing Officers’ Response: The Hearing Officers have been informed that the benefits from

the new fugitive dust rule and the NCDOT’s dust ordinance will not be included in the final

Regional Haze SIP since the impact on visibility impairment from course matter and soils is

minimal on the 20% worst days in the baseline period. In the future Regional Haze SIP, the

NCDAQ will assess if benefits from these rules will need to be addressed.

SEVIC: SEVIC expressed concerns about the public review process on material and

information that the NCDAQ said it would include in response to comments received from the

Federal Land Managers. Such materials and information include 1) details regarding “North

Carolina’s impact” on class I areas outside the State, 2) summaries of BART determinations for7 

### sources outside North Carolina which impact the class I areas in the State, and 3) a final smoke

management plan for the State.

Hearing Officers’ Response: The information regarding sources in North Carolina that may

impact Class I areas outside the State is include d in Appendix J – Consultation Process, just not

detailed in the Regional Haze SIP narrative or Appendix H narrative. The NCDAQ plans to add

a brief summary of this information in the narrative.

The BART determinations for sources outside of North Carolina will undergo the public

comment process through the state SIPs for which the sources reside. Since the NCDAQ has no

jurisdiction over those sources, the NCDAQ was only going to summarize information other

states provided with respect to this. Since this is an informational item in response to comments

and does not represent a significant change to the Regional Haze SIP, an additional public

comment period is not required.

With respect to the NCDAQ’s response to comments regarding the NCSMP, the NCSMP will

not be submitted as part of any SIP at this time and therefore is not subject to the SIP public

review process. The United States Fish and Wildlife Service requested that the NCDAQ certify

to the USEPA that North Carolina has an acceptable smoke management program. This is not a

SIP process but rather a notification process.

USEPA: The USEPA provided comments that suggested word changes and requested

clarification or further discussion of select items.

Hearing Officer’s Response: It is the recommendation of the Hearing Officers that the

NCDAQ address all of the USEPA’s comments in the final Regional Haze SIP.

Recommendation:

It is our opinion that the NCDAQ can adequately address the concerns raised by the interested

parties. Based on the information contained in this report, we recommend the following:

We recommend that the “Regional Haze State Implementation Plan for the North Carolina Class

I Areas” and the BART determinations and the related air quality permits be approved to move

forward after addressing the hearing officers’ recommendations as described in the body of this

report.8 

### Attachments to Report:

(1) Paul Dickens, Manager Environmental Affair s for Blue Ridge Paper Products, copy of oral

comments given at the November 13, 2007, public hearing in Asheville, North Carolina.

(2) Paul Dickens, Manager Environmental A ffairs for Blue Ridge Paper Products, written

comments dated November 16, 2007.

(3) Wib L. Owen, Director for North Carolina Division of Forest Resources, written comments

dated November 14, 2007.

(4) Ross Smith, Manager Environmental Affairs for PCS Phosphate Company, copy of oral

comments given at the November 15, 2007, public hearing in Washington, North Carolina.

(5) A. Preston Howard, Jr., President for Ma nufacturers and Chemical Industry Council of

North Carolina, written comments dated November 20, 2007.

(6) John R. Cline, Counsel to the Southeast Visibility Industry Coalition, written comments

dated November 16, 2007.

(7) John R. Cline, Counsel to the Southeast Visibility Industry Coalition, written comments

dated November 26, 2007.

(8) Kay T. Prince, Chief Air Planning Branch for the USEPA, written comments dated

November 26, 2007.175 Main Street • PO Box 4000

Canton, North Carolina 28716 • 828-646-2000

Raising Your Expectations 

### Comments on North Carolina Regional Haze SIP and BART Determination

Blue Ridge Paper Products Canton Mill

Asheville, NC Public Hearing by NC Division of Ai r Quality (DAQ)

11/13/2007

Submitted by Paul Dickens

Manager Environmental Affairs, Canton Mill

11-16-2007

The Canton Mill appreciates the opportunity to part icipate in the public comment process. We

support the Division’s October 2007 Regional Haze State Implementation Plan (SIP).

Development of the NC Regional Haze SIP was Well Managed

As one of sources affected by the Regional Haze Rule, we have closely monitored the planning

process followed by North Carolina and the other VISTAS States. We appreciate the

opportunities that North Carolina offered for the Canton Mill to provide refined data and to

comment on modeling and other analytical technique s used to reach the determinations in the

rule. The Division of Air Quality and VISTAS did a good job communicating results and

involving all stakeholders in th e rule development process. The process was well managed.

North Carolina is fortunate to have the professional and technically strong staff that led

development of the Regional Haze SIP and review of Best Available Retrofit Technology

(BART) demonstrations.

SEVIC Comments on the NC Regional Haze SIP

The Canton Mill is a member of SEVIC – the Sout heastern Visibility Industry Coalition. SEVIC

has prepared detailed comments on the North Ca rolina Regional Haze SIP. We endorse the

comments that SEVIC will file by the close of th e public comment period. The Canton Mill and

SEVIC believe that North Carolina reached th e correct decisions under the Federal Regional

Haze Rule for Further Reasonable Progress (FRP) and for BART. The SEVIC comments offer

suggestions to strengthen the North Carolina Regional Haze SIP. We ask the Division to

consider these comments.

VISTAS Analysis of Visibility Improvement

The VISTAS analysis of visibility improvement for the 2018 planning peri od is a technical and

detailed work. The analysis demonstrates that SO2 emissions are the primary cause of visibility

impairment in the southern mountains and that 76 percent of these SO2 emissions originate from

the electric generating units (EGUs ) in the region. Only 20 per cent of SO2 emissions in the

### Canton Mill Comments on NC Regional Haze SIP

11-13-2007, Page 2

Blue Ridge Paper Products Inc

175 Main Street • PO Box 4000

Canton, North Carolina 28716 • 828-646-2000

Raising Your Expectations 

### VISTAS region are from industrial point sour ces. The VISTAS analysis forecasts an

overwhelming visibility improveme nt in the southern mountains from EGU control measures

already in place in law. Western North Caro lina will easily meet the 2018 reasonable progress

visibility improvement goal.

Parity in Cost of SO2 Controls Between EGUs and non-EGUs

Given the overwhelming improvement that will be achieved, the stat e’s decision for parity in the

reasonable cost of SO2 controls between EGU sources and non-EGU industrial sources including

the Canton Mill is appropriate and correct. The parity decision is that the cost of SO2 controls in

dollars per ton for the non-EGUs should not exceed the cost of SO2 controls for the EGUs under

the North Carolina Clean Smokestacks Act. It allows the Canton Mill and other industrial

sources to devote resources to energy efficiency pr ojects in the near term . It provides time for

industrial sources to determine th e appropriate future mix of en ergy production in light of many

changes expected in how our nation generates energy in coming years.

Canton Mill Coal and Energy Use

The Canton Mill burns coal to make steam. However, coal is only a part of our energy mix. We

wish to place the following facts about our use of coal in the public record:

• In 2006, 45 percent of Canton Mill steam pr oduction was generated from biomass, a

renewable resource.

• The coal burned by the Canton Mill has a low to moderate sulfur c ontent and is cleaner

than allowed by our air permits.

• Our coal-fired industrial boiler capacity is small compared to the EGUs - less than 25

percent of the heat input of the average EGU in our region.

• The Canton Mill uses a combined heat and power steam cycle for generating electricity

and process heat. Combined heat and power is a much more efficient use of coal energy

than the steam cycle used to generate electr icity at an EGU. We achieve heat input

efficiencies of up to 65 percent from coal whereas a typical EGU achieves a heat input

efficiency of 35 percent.

• The annual SO2 emissions reported by the Canton Mill are overstated. This is because

we calculate SO2 emissions based on fuel sulf ur analysis. We take no credit for the SO2

emission reductions that actually occur in our power boiler pollution controls. Our

method of SO2 emission reporting is a conserva tive approach to ensure compliance with

air permit limitations, but it results in an ove rstated regional haze impact from the Canton

Mill in VISTAS modeling.

### Canton Mill Comments on NC Regional Haze SIP

11-13-2007, Page 3

Blue Ridge Paper Products Inc

175 Main Street • PO Box 4000

Canton, North Carolina 28716 • 828-646-2000

Raising Your Expectations 

### • The Canton mill has made improvement in energy efficiency since the base years used in

VISTAS modeling to determine visibility im pairment contributions. In 2006, the Canton

Mill total energy input was 11 percent less than in 2001 on an absolute basis. The energy

efficiency improvement on a production-normalized basis was 17 percent.

• We believe that the Canton Mill will have opportunities in the next 5 to 10 years to

increase the portion of energy generated from renewable sources. We will also continue

to improve our efficiency of energy use.

Canton Mill BART Demonstration

The BART eligible sources at the Canton Mill are the Recovery Furnaces. Because of

proximity to Shining Rock and to the Great Smoky Mountains, the Canton Mill was required to

prepare a detailed BART Demonstration. The demonstration included m odeling of visibility

impacts from recovery furnace emissions, evaluati on of technical feasibi lity and the cost of

additional controls, and the pot ential visibility improvement from additional controls.

The Canton Mill BART Demonstration was submitted to North Carolina in November 2006.

The demonstration documents that the BART-eligib le sources at the Canton Mill are currently

well-controlled. There are no practi cal or cost-effective additional c ontrols to apply for visibility

improvement. North Carolina accepted the Cant on Mill BART Demonstration as complete in

August 2007 after review and comment by both the Federal Land Managers and EPA Region IV.

In the October 2007 public notice for the Regiona l Haze SIP, North Carolina proposes to add

Specific Condition 2.4 to the Canton Mill Title V air permit. The proposed permit modification

establishes “no additional controls” as BART for the Recovery Furnaces at the Canton Mill.

The Canton Mill fully supports the proposed Titl e V permit modification to include BART as

“no additional controls”.laura Booth

NC Dept. of Environmental and Natural Resources

Division of Air Quality

1641 Mail Service Center

Raleigh, NC 27699-1641 

# AVA

NCDENR North Carolina

Department of Environment

And Natural Resources

Michael F. Easely, Governor

William G. Ross, Jr., Secretary North Carolina

Division of Forest Resources

Wib L. Owen, Director

November 14, 2007

Subject:

Dear Laura: NC Division of Forest Resources comments on:

NC's Regional Haze State implementation Plan prepared by NCDAQ

The DFRappreciates this opportunity to work closely with DAQ as both Divisions develop, protect, and manage

the natural resources for NC. Through our agencies cooperation and professional stewardship, the enhancement

of NC's natural resources is promoted as well as the quality living experience for NC's citizens.

The DAQ recognizes that federal land managers are afforded, by the Code of Federal Regulations Part 51, the

means to evaluate, develop, and review NC's Regional Haze State Implementation Plan. Extending this courtesy

to the DFR promotes cooperation and most importantly, synchronizes both agencies efforts in making progress in

air quality as stated under the Clean Air Act.

I would like to specifically reference the need for an editing change in Appendix H where it states, "NCDAQ

anticipates including the smoke management program as part of the final Regional Haze SIP submittal in

December, 2007" a suggested wording has been provided for in the Division's attached comments. In addition,

we have some concerns relative to the Summary of Regional Haze Comments from FLMs where it states,

"NCDAQ intends to certify the SMP as a separate action from the regional haze SIP once the SMP has been fully

reviewed by all relevant parties". We request a meeting to discuss these and other concerns.

Again, the DFRappreciates this opportunity DAQ has provided. You will find attached to this letter our comments

and proposed changes. We look forward to your response and future opportunities to work together. If you

require further information or have questions concerning our comments, please initiate direct contact with our

Fire Environment Branch. This point of contact is Gary M. Curcio, Fire Environment Forester. He is best accessible

by telephone, 919-810-5623 or can be reached by email at garv.curcio@ncmail.net.

Wib L. Owen

cf: Keith Overcash

Larry Such

David Lane

Gary Curcio

1616 Mail Service Center, Raleigh, North Carolina 27699-1601

Phone: 919 -733-2162 \ FAX: 919 -733-0138 \ Internet: www.dfr.state.nc.us

AN EQUAL OPPORTUNITY \ AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED / 10% POST CONSUMER PAPERNCDFR Comments Concerning the NC Regional Haze State Implementation Plan

1 | Page 

### FEWG – A WORKING GROUP FOR NCDFR MTM

In the Regional Haze SIP Narrative there are several references made to the “smoke management

program”. The Division advocates this wording be changed throughout the document and supporting

Appendices by using Regional Haze terminol ogy. Using such terms as smoke management

techniques, practices or plans are most appropriate. This position has been formed for several reasons.

It stays closer to the rule’s terms. It acknowledges that what is already currently in place, smoke

management techniques, is adequate and working. When assessing impacts to Class 1 Areas in 2002,

prescribed fire was not found to be a major contributor. This same result was determined when

projecting prescribed fire impacts in 2018. The NC Smoke Management Program currently being

drafted is outside of the Regional Haze State implementation Plan. The Program explains and

promotes smoke management techniques, practices or plans. By using only Regional Haze terms,

NCDAQ and NCDFR clearly ensure and retain within the state of NC the sole c apability to modify NC’s

Smoke Management Program as it is needed. It is most important that NC retain the ability for full

flexibility to make Program enhancements. Referenci ng the Program or pursuing Program certification

may jeopardize the Program’s independence and place it procedurally under an undo administrative

burden.

Recommended changes in the Regional Haze SIP Narrative

p. iii Regional Haze SIP States must also consider ongoing control programs, measures to mitigate construction activities,

source retirement and replacement schedules, smoke management programs techniques, practices or plans for agriculture

and forestry, and enforceability of specific measures.

p. 3 Regional Haze SIP During development of the long

‐ term strategy, states are also required to consider

specific factors such as the above mentioned ongoing control programs, measures to mitigate construction

activities, source retirement and replacement schedules, smoke management techniques, practices or plans for

agriculture and forestry, and enforceability of specific measures (see 40 CFR 51.308(d)(3)).

p. 46 Regional Haze SIP In addition to accounting for specific emission reductions due to ongoing air pollution

programs as required under the regional haze rule section 308 (d)(3)(v)(A), states are also required to consider

the air quality benefits of measures to mitigate the impacts of construction activities [section 308(d)(3)(v)(B)]

and agricultural and forestry smoke management techniques, practices or plans [section 308(d)(3)(v)(E)]. These

state measures are discussed in more detail in Appendix H.

Since Appendix H is referenced here the following is from Appendix H Regional Progress Evaluation and

Long Term Strategy and is recommended for change

.

p. 74 Appendix H Section 308(d)(3)(v) of the regional haze rule lists several factors that must be

addressed in each SIP. These factors include the role of fire at Class I areas and status of state planning

for managing smoke management

, the role of dust and fine soil at Class I areas and status of state plans

to mitigate emissions from construction activities and the role of NH3 and potential benefits if emissions

from agricultural sources were mitigated.NCDFR Comments Concerning the NC Regional Haze State Implementation Plan

2 | Page As discussed in Section 4.1 and demonstrated in Figure 4

‐ 1, elemental carbon (sources include

agriculture, prescribed wildland fires and wildfires) is a relatively minor contributor to visibility

impairment at the Class I areas in North Carolina. However, the NCDAQ is currently working

with the North Carolina Division of Forest Resources to develop manage and improve smoke

management techniques, practices, and plans

. that addresses the issues laid out in EPA’s 1998 draft

guidance for smoke management p lans. NCDAQ anticipates and NCDFR plan to review annually

including the smoke management. program as part of the final Regional Haze SIP submittal in

December, 2007, and for the Since present and projected smoke management efforts are working and

with planned annual reviews to evaluate smoke management techniques, practices, and plans, this

course of action is deemed resulting plan to be sufficient to satisfy the directive in section

308(d)(3)(v)(E).

p. 89 Regional Haze SIP Section 308(d)(3)(v) of the regional haze rule lists several factors that must be addressed

in each SIP. These factors include the role of fire at Class I areas and status of state planning for managing

smoke, management

, the role of dust and fine soil at Class I areas and status of state plans to mitigate

emissions from construction activities, and the role of NH3 and potential benefits if emissions from agricultural

sources were mitigated.

p. 89 Regional Haze SIP As discussed in Section 2.4 and demonstrated in Figures 2.4

‐ 1 and 2.4

‐ 2, elemental

carbon (sources include agriculture, prescribed wildland fires, and wildfires) is a relatively minor contributor to

visibility impairment at the Class I areas in North Carolina. However, the NCDAQ is currently working with the

North Carolina Division of Forest Resources to develop manage and improve smoke management techniques,

practices, and plans

. that addresses the issues laid out in EPA’s 1998 draft guidance for smoke management

plans. NCDAQ anticipates and NCDFR plan to review annually inclu ding the smoke management. program as

part of the final Regional Haze SIP submittal in December, 2007, and for the Since present and projected smoke

management efforts are working and with planned annual reviews to evaluate smoke management techniques,

practices, and plans, this course of action is deemed resulting plan to be sufficient to satisfy the directive in

section 308(d)(3)(v)(E).

p.99 Regional Haze SIP The NCDAQ also commits to ongoing consultation with the FLMs throughout the

implementation process, including annual discussion of the implementation process and the most

recent IMPROVE monitoring data and VIEWS data. To improve strategic planning, the NC Division of Forest

Resources will be included in consultations with the FLMs or receive from NCDAQ comprehensive briefings as to

implementation plan status and progress as to revisions.

Appendix D Emissions Preparations and Results

This is a comment concerning Appendix D Emissions Preparations and Results. There is much work and needed

improvement for an accurate consistent database that truly identifies NC’s natural resource management

contribution to emissions inventory. It is understandable that a methodology had to be developed in order to

address challenges and questions presented by the Regional Haze State Implementation Plan. However, it

would serve NC’s interests to have a better database that identifies the signatures of smoke generated by

various sources. Land clearing does involve the burning of woody debris. However, it is not considered a natural

resource management practice and needs to be separately identified and inventoried. This would be true for

any burning that is not under natural resource management objectives. This requires a joint effort by NCDAQ

and NCDFR as well as appropriate funding to create a real time web based database with GIS application.

Database improvements were raised by EPA during recent conference calls as a responsibility of the State Air

Regulators. NCDFR recognizes the need for this to be a joint effort in order to meet this responsibility.NCDFR Comments Concerning the NC Regional Haze State Implementation Plan

3 | Page Appendix J Consultation Process

Federal Land Managers Comments

National Forests in NC

. The NCDFR supports the comments provided by the USDA FS FLMs. However, the

Division is going a step further and recommending that there is no mentioning of the North Carolina Smoke

Management Program (NC SMP) as an Appendix or referenced in the Regional Haze SIP (as on page 86 or any

other document and its pages). It is very important for NC that NCDAQ and NCDFR maintain maximum flexibility

to modify the NC SMP on an as needed basis without having to go through a SIP revision, or waiting for long

periods of evaluation such as prescribed by the Regional Haze review cycle or any other lengthy EPA review

process. The most important fact is that current and projected emissions indicate that smoke management

techniques are working in the Class 1 Areas. These results speak for themselves and inclusion of the NC SMP is

not necessary. Also, NCDAQ and NCDFR with its Strategic Partners will be conducting interagency annual reviews

on the status of natural resource management smoke.

U.S. Fish and Wildlife Service and National Park in NC. NCDFR supports the comments provided by the USDOI

FLMs. They state “We do, however, recommend that the State “certify” the SMP as provided for in EPA’s

“Interim Air Quality Policy on Wildland and Prescribed Fire”. The NCDFR respects USDOI position. However, for

reasons mentioned under the National Forests in NC, the Division does not what to pursue certification. Smoke

management techniques, practices, and plans are working and if and when it is in the best interest of NC,

NCDFDR will pursue this course of action. Through use of good stewardship practices that are adaptable, NC will

maintain maximum flexibility to do what is best for the citizens and natural resources in NC. Also, this policy is

an interim policy. Final EPA Wildland and Prescribed Fire Policy are due for publication in July 2008. The NCDFR

recommends the utilization of what is presently working and to implement improvements once NCDAQ and

NCDFR complete current drafts.

NCDAQ’s Summary of Regional Haze Comments from FLMs

p. 2 7. The US Fish and Wildlife Service and National Park Service recommend that the State “certify” the

Smoke Management Plan. NCDAQ Response: NCDAQ intends to certify the SMP as a separate action

from the regional haze SIP once the SMP has been fully reviewed by all relevant parties.

In previous conversations with NCDAQ the intention to certify the NC SMP has not been discussed as a

course of action to pursue. Also, conversations between NCDFR and EPA on this subject, the

development of new air quality rules, and an interim policy that is to become final policy within six

months, indicates that this course of action is not necessary. The present system is working. Also, there

is already under development improvements in smoke management techniques, practices, and plans.

Before any action is taken to certify the NC SMP by NCDAQ, the NCDFR would like to discuss this

proposed action with the Division’s Strategic Partners. NCDAQ is a strategic partner as well as the FLMs

and other NC entities.