# Appendix O.3

Georgia EPD Responses to FLM Comments on Draft Prehearing SIPAppendix O.3

Georgia EPD Responses to Federal Land Manag er Comments on the Draft Prehearing SIP

Responses to U.S. Forest Service Comments

1. page V – For the 20 percent worst days th e Reasonable Progress goal should be 7.45 and not 7.47; and the deciview (dv) improveme nt needed by 2064 should be 12.02 dv and not

12.00.

Response: This comment appears to pertain to th e deciview improvement values given for the Cohutta Wilderness Area on page v of th e Executive Summary. EPD believes that the

7.47 value is correct. Table 2.3- 1 identifies the baseline visib ility as 30.25 dv and Figure 8.0-1 shows the reasonable progress goal to be 22.78 dv. The actual deciview targets have been added to the table on page v for clarity.

2. page 4 – Joyce Kilmer, Tennessee should be identified as Joyce Kilmer – Slickrock Wilderness Area, North Carolina and Tennessee.

Response: Revised as requested.

3. page 6 (2 nd paragraph) – Here and elsewhere in the document the following statement can be removed: “Note that on July 11, 2008 ...”

Response: Revised as requested.

4. page 11 – We concur with using the New IMPROVE equation.

Response: Noted – no change required.

5. page 12 (1 st paragraph) – We would recommend the following phrase, “The 20 percent best visibility days at the Southe rn Appalachian sites ...” be ch anged to “The 20 percent best visibility days at Cohutta Wilderness ...”

Response: Revised as requested.

6. page 14 (1 st paragraph) – Should read as “... wildfires or pres cribed fires.”

Response: Revised as requested.

7. page 15 (3 rd paragraph) – Please add to the end of the 1 st sentence “... in comparison to the former IMPROVE equation.”Response: Reworded for clarification.

8. page 17 – The values in Figure 3.1-1 shoul d be listed to only two decimal places.

Response: Corrected.

9. page 24 – there is no image on Figure 4.2- 1. (SO2 emissions in 2002 in the VISTAS States).

Response: Corrected.

10. page 40 – We recognize the lack of IM PROVE data contributed to assessing model performance at Cohutta Wilderness and we c oncur with the methods in Appendix B to substitute data from Great Smoky Mountains National Park on the days the Cohutta monitoring site was missing data.

Response: Noted – no change required.

11. page 46 – We are recommending that the Smoke Management Plan (SMP) document should not be included in Appendix H.10, but instead a reference should be made (as was done on page 103) that Georgia does operate un der a SMP. Our concern is that Georgia may lose maximum flexibility to modify the SMP on an as needed basis without having to go through a SIP revision, or waiting for long pe riods of evaluation such as prescribed by the Regional Haze review cycle. As stated in the pre-draft SIP, we concur with your finding that wildland fire emi ssions are not a significant contributor to visibility impairment at the Class I areas and further emission reduction techniqu es from prescribed fires are not needed before 2018. Based upon th is finding, it appears the current prescribed fire smoke management techniques implement ed in Georgia are adequate to protect visibility in the Class I areas. If you concur , we suggest your agency note this finding in the final SIP. Also, you may want to note that your agency and the Georgia prescribed fire community are continuing to work together to refine the smoke management techniques to address ecological, human health and welfare needs.

Response: The Smoke Management Plan has been re moved as suggested. The plan is still referenced from Subsection 7.8 of the narrati ve and from Subsection 10.2 of Appendix H.

12. page 50 – Figure 7.2.4-1 please remove “ew IMPROVE Al_orith” from the graphic.

Response: Corrected.

13. page 70 (1 st paragraph) – Please delete the words “... most current ...” and just say “... were developed using the Base G VISTAS 2002 base year ...”

Response: Revised as requested.14. We are recommending the VISTAS Area of In fluence (AOI) electronic spreadsheet that includes all sources be included in the Appe ndices. Appendix H.5 only includes the BART eligible sources.

Response: The VISTAS Area of Influence (AOI) el ectronic spreadsheet that includes all sources is already included in th e SIP. Please see Appendix H.2

15. We agree that the Reasonable Progress approach used in this first Regional Haze SIP is a good approach and we appreciat e the State of Georgia ut ilizing a lower Q/d (source emissions divided by distance to the Class I area ) value in comparison to other southeastern

states.

Response: Noted – no change required.

16. The pre-draft SIP does not discuss how emissions from all significant stationary sources in Georgia will affect visibility in Class I areas outside of Georgi a; specifically Joyce KilmerSlickrock, Linville Gorge, Shining Rock and Sipsey Wildernesses. The information is contained in the VISTAS Area of Influence ( AOI) analyses and it woul d be appropriate to discuss how emission changes planned for all of Georgia sources (not only BART sources) will affect visibility at Class I areas in other states. There are three sections of the Regional Haze Rule that we believe support our request:

a. 51.308 (d)(3) Long term strategy . "Each State... must submit a long-term strategy that addresses regional haze visibility impairment...for each mandatory Class I

Federal area located outside the State wh ich may be affected by emissions from the State. The long-term strategy must include enforceable emissions limitations, compliance schedules, and other measures as necessary to achieve the reasonable progress goals established by States having mandatory Cl ass I Federal areas."

b. 51.308 (d) (3) (i) "Where the State has em issions that are reasonably anticipated to contribute to visibility impairment in any ... Class I area located in another State..., the State must consult with th e other State(s) in order to develop coordinated emission manage ment strategies."

c. 51.308 (d) (3) (ii) "If the State has particip ated in a regional planning process, the

State must ensure it has included a ll measures needed to achieve its apportionment of emission reduction ob ligations agreed upon through that process."

Section 10, ‘InterState Consultation’, should in clude a list of Georgia sources the AOI identified as having a potent ial to impact the Class I areas in Alabama and North

Carolina. The list also needs to include th e pollution reductions that are anticipated at

each source before 2018.Response: Added Tables 10-1 thru 10-7 documen ting the impact from Georgia’s point sources on Joyce Kilmer-Slickrock (NC), Shining Rock (NC), Great Smoky Mountains (NC/TN), Sipsey Wildernesses (AL), Cape Romain (SC), Swanquarter (NC), and St. Marks (FL). All other Class I areas showed contributions fr om Georgia point sources of less than 0.5%. A table (7.6.1-1) of Georgia EGUs for which CAIR constitutes reasonable progress was added to Section 7.6.1. The table presents the emissions reductions expected prior to 2018. The pollu tion reductions associated with sources going through four-factor analysis are already presented in Section 7.6.

17. page 114 – We are recommending that the year the first 5-year pr ogress report will be completed also be included in the first paragraph.

Response: The second paragraph of Secti on 11.0 (Comprehensive Periodic Implementation Plan Revisions) states that EPD “commits to submitting a report on reasonable progress to US EPA every five years follo wing the initial submittal of the SIP” as required by 40 CFR 51.308(g). Because the date of the initial submittal to EPA (and EPA’s approval) is unknown at this time, EPD is reluctant to specify the year for the first progress report. EPD feels that the current statement in Section 11.0 is satisfactory.Responses to U.S. Fish and Wildlife Serv ice and National Park Service Comments

[1]* International Impairment

On page 58, a modified glide sl ope is presented. This glide slope is based on removing the international emissions. However, the intern ational component was not removed from the

natural conditions. The result eff ect is minor, but should be correct ed in the final version of the

SIP.

* The comment number in brackets was assigned by Georgia EPD for ease of reference. There were no comment numbers in the p ackage of comments from FWS/NPS.

Response: In accordance with EPA recommendations, EPD did not alter the uniform rate of progress glide slope. Since the natural conditions for visibility does not include international components, EPD believes it would be inappropriate to remove them from the glide slope. EPD did alter the location where the future model projec tion falls with respect to the uniform rate of progress glide slope.

[2] Best Available Retrofit Technol ogy (BART) and Reasonable Progress (RP)

On page 78, the draft SIP states, “In accord ance with Environmental Protection Agency guidance, emission units subject to BART revi ew are not subject to reasonable progress goal review.” The State does have the option of requiring additional controls, if BART is not sufficient enough to reach reasonable progress goals.

Response: EPD has changed the wording of this stat ement to better reflect the wording used on page 4-2 of EPA’s June 1, 2007 memorandum “Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program” by the Office of Air Quality Planning and Standards.[EM]

[3] Smoke Management Plan

On page 103, the Smoke Management Plan (SMP) should be referenced in a summary paragraph

and the SMP should be included as an Appendix to the SIP. The summary paragraph should include whether the SMP is voluntary or mandato ry and whether the SMP includes Class I areas as a sensitive receptor. Additionally, some basi c statements should be included as to whether emissions from fire are anticipated to shrink, stay the same, or increase over the ten year planning period. It is recomme nded that the SMP should be refe renced in a manner that does not require SIP updates each time the SMP is updated.

Response: EPD concurs and has removed the SMP fr om the appendix and the reference to the appendix containing the SMP.[4] Construction Activity

The draft SIP does not contain a discussion on State limits on emissions resulting from construction activity. This is a requir ed element of the Regional Haze SIP.

Response: Section 7.8 of the SIP narrative and Secti on 10.2 of Appendix H have been revised to address emissions from construction activities. Georgia’s Rules for Air Quality Control include requirements for precautions to prevent fugiti ve dust from becoming airb orne and also limit the opacity of fugitive emissions to less than 20 perc ent. The requirements of rule 391-3-1-.02(n) include preventive measures for construction ac tivities and are deemed adequate to satisfy the directive in section 308(d)(3)(v)(B) of the Regional Haze rule.

[5] Impact on out-of-State Class I areas

The draft SIP should contain a few statements on Georgia’s impact on out-o f-State Class I areas.

Response: Added Tables 10-1 thru 10-7 documenting the impact from Georgia’s point sources on Joyce Kilmer-Slickrock (NC), Shining Rock (NC) , Great Smoky Mountains (NC/TN), Sipsey Wildernesses (AL), Cape Romain (SC), Swanquarter (NC), and St. Ma rks (FL). All other Class I areas showed contributions from Geor gia point sources of less than 0.5%.

[6] Best Available Retrofit Technology (B ART) Provisions of the Georgia Regional

Haze SIP

Appendix H of the Georgia Regional Haze State Im plementation Plan – Draft (RH SIP) contains BART Exemption Modeling Reports for a number of facilities, but such reports are not included for eight BART-eligible sources. They are: DSM Chemicals North America, Georgia PacificBrunswick Cellulose, Owens Corning, PCA, PCS Nitrogen, Prayon, Inc., Rayonier and Tronox/Kerr-McGee. Please provide these reports in the record as eviden ce to confirm that none

of the above facilities im pact any Class I area by 0.5 deciviews or greater.

Response: Reports for the above mentione d facilities have been added and placed in the folder called BART Protocols and Exemption Modeling reports

[ 7 ] It is important that the RH SIP be clear that the Georgia EPD is the entity that accepts and adopts required emission cont rols, because the EPA BART Gu idelines require that permit

conditions be finalized and included in the RH SIP. 1 Section 7.7.3 implies that Interstate Paper in Riceboro developed the BART determination in the reference, “Their BART determinationresults . . .” However, on a January 22, 2009 confer ence call Georgia EPD stated that the BART determination was developed by the State. Thus , the wording should be clear that the Required Control Options displayed in Ta ble 7.7.3-1 are the conclusions of Georgia EPD, rather than merely results presented by Interstate Paper. In the next-to-last paragraph of Section 7.7.2, relating to Georgia Pacific - Ce dar Springs, Georgia EPD should ma ke it clear that the stated emission limits are accepted and adopted by the State.

1 See 40 CFR Part 51, Appendix Y. The U.S. Environmental Protection Agency finalized it’s BART Guidelines on June 15, 2005, and published the preamble and final rule text in the Federal Register on July 6, 2005. The rulemaking action added Appendix Y to Part 51, titled “Guidelines for BART Determinations Under the Regional Haze Rule.” See Section V.

Response: EPD added language to identify that the BART determination was performed by EPD and the resulting conclusions are EPD’s.

No change is necessary for the comment concer ning GP Cedar Springs. The permit for this source is being amended and is not yet final. The Narrative states that the permit will be amended. No conclusive statement can be made until the permit is final.

[8] The “model plant” criteria for Interna tional Paper – Savannah and Lafarge Building

Materials – Atlanta should be documented. Ta ble 7.7.2-2 makes reference to exempting these

facilities from BART based on “Model Plant Criter ia”, but the term has not been defined in the

RH SIP. The EPA BART Guidelines define what could be accepted by a state as a model plant

criteria 2 , but allows a state to develop its own criter ia. The RH SIP should state or reference the

State’s definition of “Model Plan t Criteria” and it should also s how the definitive distance and

emission characteristics of the above two facilities so as to confirm their meeting the “Model

Plant Criteria”.

2 Ibid, Section III.A.3.Option 2.

Response: EPD added language that defines the mode l plant criteria. In addition, emissions and distance from the closest Class I area for each facility listed were added to Table 7.7.2-2.

[9] Regarding the BART determination for Interstate Paper-Riceboro, Table 7.7.3-1, under the heading “Required Control Option” for the Li me Kiln states, “No co st effective control options Available.” As discussed below there are cost-effective (i.e., cost per ton) control options available for the lime kiln, but as you clarified on a January 22, 2009, conference call,

the lack of cost-effectiveness was on the basis of excessive cost of visibility improvement. Please clarify this in Section 7.7.3. For the record it should be noted that cost-effective (i.e., cost per ton) control options are ava ilable for the lime kiln. The control alternatives of SNCR-NH3 based, SNCR-Urea based and Low NO

x burner are all under $1,500 per ton of NO

x reduced. It should be noted that only summary cost data we re presented. More detailed cost informationshould be included in BART determinations so that third-party review ers can more thoroughly

review the costs and methodol ogies that were used.

Response: More detailed informa tion on the control options c onsidered is available in Appendix H.8. Also, note that there is little impact on visi bility from NOx. Because of this, NOx controls are not cost effective no matter whic h control is considered. Therefore, EPD has decided to focus on SO2 contro ls rather than NOx controls.