Appendix J 

Consultation Process 
Appendix J - 1
1. Introduction 

The Southeast Regional Planning Organization, Visibility Improvement State and Tribal 

Association of the Southeast (VISTAS), is comprised of the ten Southeast States 

(Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, 

Tennessee, Virginia and West Virginia) and the local programs and tribal agencies 

located within these states. 

The VISTAS states have jointly developed the technical analyses to define the visibility 

improvement by 2018 under existing federal and state regulations compared to the 

uniform rate of progress, sulfur dioxide (SO2) Areas of Influence for each Class I area, 

and methods to prioritize contributions from individual sources within the Areas of 

Influence. The states collectively accepted the conclusions of these analyses. 

In December 2006, the VISTAS State Air Directors held their first formal consultation 

meeting to review the latest modeling results and the SO2 Areas of Influence analyses. 

The Air Directors agreed to look at reasonable control measures for sources on the lists 

for the SO2 Areas of Influence. Each state would consider sources within their state and 

would identify sources in neighboring states that they would like to have that neighboring 

state consider. 

States acknowledged that the review process would differ among states since some Class 

I areas are projected to see visibility improvements near the uniform rate of progress 

while most Class I areas are projected to have greater improvements than uniform rate of 

progress. 

In May 2007, the VISTAS State Air Directors met for their second formal interstate 

consultation. States shared their lists of sources in their state and neighboring states for 

each Class I area. They also shared their criteria for listing sources and their plans for 

further interstate consultation. 

The South Carolina Department of Health and Environmental Control (SC DHEC) has 

evaluated the impact of South Carolina sources on Class I areas in neighboring states and 

determined that there are no additional reasonable control measures that should be 

implemented to mitigate impacts in Class I areas in neighboring states. SC DHEC has 

consulted with the responsible states regarding its evaluation showing no cost-effective 

controls available for those units contributing at least 0.5 percent to visibility impairment 

at Class I areas. 

Analyses of impacts from South Carolina sources and potential controls are discussed in 

greater detail in Appendix H. Consultation letters may be found attached to this 

Appendix. 

Neighboring states are still in the process of evaluating BART and reasonable progress. 

Appendix J - 2
The Mid-Atlantic/Northeast Visibility Union (MANE-VU) states of New Jersey and New 

Hampshire sent letters to South Carolina in the spring of 2007 stating that based on 2002 

emissions, South Carolina contributed to visibility impairment to Class I areas in those 

states. 

The MANE-VU states have asked the SC DHEC to participate in further consultation 

with these states during the summer of 2007. SC DHEC participated in these 

consultation meetings, and the final Regional Haze State Implementation Plan will reflect 

the results of those meetings. 

The letters from these states and other interested parties, and responses from SC DHEC, 

are included as attachments to this Appendix. 

Appendix J - 3
2. Consultation Letters 

Below is a list of the consultation letters and responses to date. 

Letter: 10/10/2006, Charles D. Myers, U.S. Department of Agriculture letter outlining 

what they will be looking for in SIPs, providing a point of contact and requesting key 

points of contact on SC DHEC staff....................................................................................6 

Letter: 8/1/2006, Sandra V. Silva and Christine L. Shaver, U.S. Fish and Wildlife Service 

and National Park Service letter to discuss their interests with respect to the Regional 

Haze SIP development.......................................................................................................12 

Letter: 1/18/2007, Lisa P. Jackson, State of New Jersey letter requesting consultation 

regarding impacts South Carolina has on Brigantine Wilderness area..............................19 

Letter: 3/15/2007, Robert W. King, Jr., SC DHEC’s response to State of New Jersey ....22 

Letter: 4/4/2007, Thomas S. Burack, State of New Hampshire letter requesting 

consultation regarding impacts South Carolina has their Class I areas .............................24 

Letter: 6/29/2007, Robert W. King, Jr., SC DHEC’s response to State of New Hampshire26 

Letter: 4/9/2007, Heather Abrams, State of Georgia letter discussing their four factor 

analysis for regional haze...................................................................................................28

Letter: 6/29/2007, Myra C. Reece, SC DHEC’s response to State of Georgia..................32 

Meeting Minutes: 6/12/2007, Summary of VISTAS States consultation meeting with 

Federal Land Managers and Environmental Protection Agency .......................................35 

Letter: 7/10/2007, Anna Garcia, Ozone Transport Commission invitation to participate in 

a consultation meeting with MANE-VU RPO...................................................................41 

 

Letter: 8/6/2007, Keith B. Overcash, State of North Carolina letter requesting 

consultation regarding South Carolina sources affecting North Carolina’s Class I Areas44 

Letter: 11/9/07, Myra C. Reece, SC DHEC’s response to North Carolina........................49 

Meeting Minutes: 8/20/07, Summary of VISTAS States consultation meeting with the 

MANE-VU RPO................................................................................................................51 

Letter: 10/15/07, Assistant Secretary for Fish and Wildlife and Parks, Department of 

Interior Comments on the South Carolina Regional Haze SIP..........................................55 

Letter: 12/17/07, Myra C. Reece, SC DHEC’s response to Fish and Wildlife and Parks, 

Department of Interior .......................................................................................................63 

Appendix J - 4
Electronic Mail: 10/23/07, Nacosta C. Ward, US EPA, Region 4 Comments on South 

Carolina’s Regional Haze SIP ...........................................................................................68 

Letter: 10/26/07, Hilliard, Marisue, U.S. Department of Agriculture, U.S. Forest Service 

Comments of the South Carolina pre-draft Regional Haze SIP ........................................86 

Letter: 12/17/07, Myra C. Reece, SC DHEC’s response to U.S. Department of 

Agriculture, U.S. Forest Service........................................................................................89 

Letter: 11/9/07, Robert J. Brown, SC DHEC’s pre-hearing SIP Package to US EPA ......93 

Letter: 12/14/07, Richard A. Schutt, US EPA, Region 4 Pre-hearing Comments on South 

Carolina’s Regional Haze SIP ...........................................................................................95 

Letter: 12/18/07, Myra C. Reece, SC DHEC’s response to US EPA, Region 4 .............102 

Letters: 12/7/07 and 12/12/07, Myra C. Reece, SC DHEC BART Exemption Status to 

BART-Eligible facilities ..................................................................................................109 

Letter: 12/7/07, John R. Cline, Southeast Visibility Industry Coalition comments on 

South Carolina’s Regional Haze SIP ...............................................................................126 

Letter: 12/18/07, Robert J. Brown, SC DHEC’s response to Southeast Visibility Industry 

Coalition...........................................................................................................................152 

Letter: 12/12/07, James P. Witkowski, South Carolina Chamber of Commerce 

Environmental Technical Committee comments on South Carolina’s Regional Haze SIP156 

Letter: 12/17/07, Robert J. Brown, SC DHEC’s response to South Carolina Chamber of 

Commerce........................................................................................................................164 

Letter: 12/13/07, Duane Mummert, South Carolina Pulp & Paper Association comments 

on South Carolina’s Regional Haze SIP ..........................................................................174 

Letter: 12/17/07, Myra C. Reece, SC DHEC’s response to South Carolina Pulp & Paper 

Association.......................................................................................................................182 

Appendix J - 5
Forest Southern Region 1720 Peachtree Road NW 

Selvice ' 4 Atlanta, Georgia 30309 

Myra Reece 

sc Department of Health and Environmental Control 

Bureau of Air Quality 

2600 Bull St. 

Columbia, SC 29201 - 1797 

Dear Ms. Reece: 

File Code: 25 80 

Date: October 10, 2006 

WaBUREAU OF AIR QUALITY 

Over the past several years, our staff has participated with members of your staff and those of 

neighboring states and tribes in the Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS) regional planning organization developing best approaches and tools for 

preparing the plans that will reduce haze in Class I areas. Now that preparation of your Regional 

Haze State Implementation Plan (SIP) is at hand, we want to direct our attention to a close 

collaboration directly with you and your staff to help ensure that your SIP is successhl. As you 

know, our consultation with you is required in the Regional Haze Rule (RHR). This is my 

number one priority for our air program. 

Our focus will be on Class I wildernesses for which the USDA Forest Service is responsible. 

But we have built a coordination link with the other Class I area managers, the National Park 

Service and the US Fish & Wildlife Service, to facilitate to the extent possible a common 

message fi-om the federal land managers (FLM). We anticipate that we will be able to leverage 

the strengths fi-om each of the FLMs to your advantage and to ours. Since the FLMs will be 

seeking a close working relationship with every state in this SIP-writing process, we expect to be 

able to share with you ideas fi-om across the nation. As the manager of 88 Class I areas, the 

perspective of our agency is that each of the states is contributing to a national fabric of 

emissions reductions plans that interweave and put us on the glide path towards the natural 

background objective. Thus, each and every SIP plays a critical role. 

In the enclosure, I have provided some detailed perspectives pertinent to SIP preparation. Any 

comments or questions about these perspectives should be directed to Bill Jackson, Air Specialist 

at USDA Forest Service, PO Box 2750, Asheville, NC 28802 (828-257-4815, 

b&ckson@fs fedus), your principle Forest Service point of contact in this process. He will 

provide the required Forest Service consultation on your SIP now and through the required 60- 

day comment period. Working with others on our staff, especially our National Haze 

Coordinator, Ann Mebane (307-587-4597, amebane("fs fed us), and with the DOI, he will 

provide you with our best insights and recommendations. 

As required in the RHR, at your earliest convenience, please identifjr the key point(@ of contact 

on your staffwith whom Bill may work on the SIP. Send all correspondence to both Bill 

Jackson and Ann Mebane. We would prefer this electronically to the extent possible. 

I look forward to a fruithl consultation and a successhl Regional Haze SIP 

Caring for the Land and Se&g Peopk Printed on Recyded Papa fi 

Appendix J - 6
Sincerely, - 

Enclosure 

Appendix J - 7
Enclosure (1) 

The following perspectives are merely suggestions or recomme~tions not direction or 

requirements. lhey are deliberately very similar to those prepared by the Depurtment of 

Interior to contribute to a common sense of purpose for improving haze in all Clam I areas. We 

are sending these perspectives to each state. In so rloing, we hope to facilitate inter-state 

coordination. At the same time, we fully acknowledge the dscretion aflorkd in the RHR for 

unique and creative solutions by individual states in writing plans that reduce haze. 

Natural Condition and Uniform Rate 

These factors apply mainly to States that have Class I areas. Other States that contribute to 

visibility impairment in Class I areas located in a different state might consider including 

discussion and conclusions on these factors in their individual plans. 

The basic calculation of baseline, natural condition, and uniform rate builds the foundalion for 

the entire RHR SIP process. Considerable discussion and debate at the science and policy level 

has occurred regarding appropriate methods to be used. As a consequence, several equations that 

include varying parameters or multipliers are available. Because these calculations can have a 

significant effect on the resulting progress goal, it is important to provide a detailed description 

of the methods used in the SIP. Calculations that include only portions of established methods or 

utilize unique approaches will be better understood if the rationale for these differences is hlly 

explained in the SIP or its supporting documentation. We encourage states to use calculations 

that are based on equations recommended by the IMPROVE steering committee and that are 

consistent with recommended approaches from the pertinent RPO and the Environmental 

Protection Agency (EPA) region. 

Emission Inventories 

Given the complexities associated with modem comprehensive emission inventories, spending 

some considerable effort in describing how these inventories were developed and used will be 

important. Emission descriptions will be most informative if they include an evolutionary 

discussion that includes; an actual, base-year inventory used to evaluate model performance; a 

typical, base-year inventory that represents the five year, average state which establishes 

modeled visibility impacts; and various hture year, controlPed inventories that demonstrate 

fbture visibility conditions. Consider adding kture year inventories that are clearly partitioned 

to delineate source types (by text, charts, or graphics) that are included in each model simulation. 

Benefits to fbture visibility conditions suggested in the SIP that are not also clearly linked to a 

hture inventory or are not clearly included in hture mode! analysis, will warrant additional 

discussion. 

One part of your emission inventory includes the implementation of "Best Available Retrofit 

Technology" (BART) on a subset of pre-Prevention of Significant Deterioration sources. BART 

source identification, elimination, and level determination will be of particular interest for 

review. We would prefer to see a clear progression through the three basic BART phases and a 

thorough description of the RHR prescribed factor analysis (if applicable). Consider discussing 

whether BART levels apply to individual or grouped source categories. 

Appendix J - 8
Area of Influence 

The area of influence of significant visibility-impairing sources is an important SIP element. We 

suggest that that each state clearly identifj. and apportion by State, or other geographic means, 

the significant levels of pollutants contributed to each Class I area by source. Developing this 

information together with neighboring States and Tribes will facilitate consistency. Discussions 

of changing source area contributions at both the base- and fbture-year levels will help 

demonstrate SIP progress. Consider the benefits of presenting this information in the fonn of 

transported mass by pollutant or through individually calculated visibility impairment measures. 

Using a percentage or "Top 10" raniring for current contributions by geographic area may or may 

not clearly describe progress over time. 

Reasonable Progress Gods and Long Term Strategy 

Establishing reasonable progress goals for Class I areas in your State and/or acknowledging 

reasonable progress goals for Class I areas in other States that are affected by emissions fiom 

your State, as well as defining associated emissions strategies to meet these goals, form the basis 

of the SIP process under the RHR. 

In developing the statute's required Long Term Strategy (LTS), your State is offered broad 

flexibility when determining reasonable progress goals and associated emissions. As noted 

earlier, the RHR includes a requirement for States to assess a uniform rate of progress and 

compare that rate to the reasonable progress goals set by those states with Class I areas. We feel 

that this uniform rate of progress assessment is usefbl in determining the geographic and 

economic extent a State can consider when developing the LTS associated with the reasonable 

progress goals. 

In general, we will be looking at the degree to which the LTS is supported by RPO technical 

work and at the level of consistency among the contributing States. For Class I areas where your 

State is setting a 2018 reasonable progress goal of equal or less impairment compared to the 

uniform rate of progress, our review will focus holistically on (1) whether strategies are applied 

equitably across source types, (2) if both local and regional emission strategies have been fully 

examined, and (3) how consistent assessments and strategies are applied regionally. 

For Class I areas where the reasonable progress goal is more impaired than the uniform rate of 

progress, consider presenting information on a component basis. Components could consist of 

emission source category as before, but also include contributions fiom individual pollutants or 

by geographic source area. Our intent is to better understand where and why a strategy falls 

short of the uniform progress rate goal. Because each region has focused their emission control 

strategy on different conditions, presenting results in a component format may assist in showing 

what level of progress was made in the focus area, verses other less controllable factors. 

Wildland Fire 

Your state has considerable flexibility as it addresses all anthropogenic sources of visibility 

impairment, including fire. The RHR requires consideration of smoke management techniques 

for agricultural and forestry management practices in the development of the LTS part of the 

SIP. On a short-term basis, fire, both natural and anthropogenic, has the potential to cause 

significant visibility reduction in Class I areas. If anthropogenic fire contributes to the index 

Appendix J - 9
used to track long-term, reasonable progress in a Class I area, the visibility SIP should identify 

how it will be addressed. Your state may already have a smoke management program (SMP) 

that adequately describes how visibility impairment from fire will be addressed. If fire has been 

determined to contribute to visibility impairment, we suggest including a fire emissions 

inventory along with a comment about its reliability and a projection for changes to the hture 

inventory. If your state has a SMP, is it a basic smoke management program or an enhanced 

smoke management plan? And has the SMP been certified by EPA7s Interim Air Quality Policy 

on Wildland and Prescribed Fire? Identify the specific SMP requirements for minimizing 

visibility impairment in Class I areas and classify the various types of wildland fire (wildfire, 

prescribed fire, and wildland fire use fire) as either natural or anthropogenic. Are there 

differences in state regulation for the way in which smoke from agricultural burning and forest 

fires are treated? Is there a difference in the way emissions from wildfire, prescribed fire and 

wildland-fire-use (WFU) fire are identified and treated on private, state and federal lands? 

Regional Consistency 

The RPOs have been working toward regionally-consistent approaches to address visibility 

impairment throughout the SIP development process. There may be circumstances when 

different methods were used or impairment assessments reached different conclusions. The 

FLMs understand that each State knows what emission control methods or air quality 

management strategies work best for its areas. Each State may wish to develop strategies that 

are independent from RPO or neighboring areas. 

In this context, our review of "regional consistency" will have less to do with individual 

discretion each State has in making decisions, and more on how well a group of States identifies 

and addresses similar, agreed upon goals for each Class I area within a common area of 

influence. 

Regional consistency can also be difficult to evaluate if neighboring SIPs (or portions of SIPs) 

are released for review at different times. We expect that thorough inter-State consultation 

processes will lead to consistent descriptions of apportionment and emission control goals, thus 

resulting in development of similar progress goals, regardless of release dates. 

Verification and Contingencies 

Little emphasis has been placed in the RHR on verification and even less on contingency 

planning. By rule, each SIP must identify the monitoring data used to specify the original 

baseline and also as part of an ongoing progress review at five year intervals. Given the 

uncertain hture of any individual monitoring site, we suggest that the SIP address the 

representativeness of both primary and alternative data sites for each class I area. 

Consider not only the data necessary to measure progress but also how to account for and 

mitigate both unexpected and reasonably foreseeable emissions growth, changes to the 

geographic distribution of emissions, and substantive errors that may be found in emission 

inventories or other technical bases of the SIPs. These factors, as well as other unanticipated 

circumstances, may adversely affect your state's ability to achieve the emissions reductions 

projected by the SIP. Considering these factors through adaptive management or continual 

review strategies may assist in avoiding these circumstances. 

Appendix J - 10
Coordination and Consultation 

The 1999 Regional Haze Rule requires States to consult with the Federal Land Management 

(FLM) agencies at least 60 days prior to holding any public hearing on a RHR SIP or SIP 

revision (40 CFR 51.308(i)). As named in the cover letter to this attachment, a single Forest 

Service air specialist has been assigned to your state. He will facilitate the coordination of 

comments from multiple Forest Service FLMs if they exist in your state. 

Appendix J - 11
1 

United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

National Wildlife Refuge System 

Branch of Air Quality 

IN REPLY REFER TO: 7333 W. Jefferson Ave., Suite 375 

FWS/ANWS-AR-AQ Lakewood, CO 80235-2017 

August 1,2006 

Ms. Myra Reece 

Chief, Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

2600 Bull Street 

Columbia, South Carolina 29201 

ECEllVE 

BUREAU OF AIR QUALlSY 

Subject: Regional Haze Rule Consultation with Federal Land Management Agencies 

Dear Ms. Reece: 

Over the past several years, the U.S. Fish and Wildlife Service (FWS), National Park 

Service (NPS), and Forest Service have participated in regional planning efforts 

addressing ways for States, and Tribes if they so choose, to protect and improve visibility 

in Class I national parks and wildernesses through implementation of the Regional Haze 

Rule (RHR). Along with other stakeholders, we have had many opportunities to 

contribute to ongoing Regional Planning Organization (RPO) development of policy 

guidance and technical information. As States begin to develop their regional haze State 

implementation plans (SIPS) based on RPO work, we are interested in working directly 

with your staff to offer our perspective as managers of affected Class I areas and to 

maintain our support for an effective national regional haze program. 

The primary purpose of this letter is to provide you general insights about FWS and NPS 

interests with respect to upcoming SIP development and consultation activities. It is not 

intended to dictate policy or guidance. Rather, in the enclosure to this letter we include 

discussion on a list of topics to enhance your understanding of our views on key SIP 

components. We also provide lead contacts for FWS and NPS staff that will be available 

to work with your staff during early phases of SIP development as well as coordinate the 

required formal 60-day review/consultation with the official Federal Land Manager 

(FLM) for the Department of the Interior. 

The RHR requires States to inform the FLMs of the appropriate State contact for 

exchange of information regarding SIP development. Many States provided us with a 

contact person shortly after the RHR was published. It would be helpful if you could 

confirm your contact or provide a current single point of contact for your State to the 

individuals noted in the enclosure. Additional information regarding your SIP timelines 

would also be very helpful. 

Appendix J - 12
Our highest priority in working with you over the course of the next year and a half will 

be to help you develop a successful SIP. We understand the complexities of developing a 

plan reliant on non-linear relationships between emissions and subsequent visibili~ 

improvements. Our emphasis is to work with you and, as your partners, to ensure each 

plan utilizes all reasonable means to obtain realistic goals. We share the common goal of 

improving visibility in all Class I areas throughout the United States, and we wouM like 

to use this planning process to maximize goal achievement. Our hope is that through this 

communication we can complete the RHR requirement of formal consultation with ease 

and productivity. 

We are looking forward to continuing our work with you and your staff as the regianal 

haze SIPS are developed. Please don't hesitate to contact us with questions. 

Sincerely, 

Sandra V. Silva 

Chief, Air Quality Branch 

U.S. Fish and Wildlife Service 

Enclosure 

cc: 

Forest Service: Rich Fisher, Donna Lamb 

EPA Regional Air Division Directors 

Regional Planning Organization Directors 

Christine L. Shaver 

Chief, Air Resources Division 

National Park Service 

Appendix J - 13
Fire 

Your State has considerable flexibility as it addresses all anthropogenic sources of 

visibility impairment, including fire. The RHR requires consideration of smoke 

management techniques for agricultural and forestry management practices in the 

development of the LTS part of the SIP. On a short-term basis, fire, both natural and 

anthropogenic, has the potential to cause significant visibility reduction in Class I arm. 

If anthropogenic fire contributes to the index used to track long-term, reasonable pqgess 

in a Class I area, the visibility SIP should identify how it will be addressed. Your State 

may already have a smoke management program (SMP) that adequately describes how 

visibility impairment fiom fire will be addressed. Iffire has been determined to 

contribute to visibility impairment, the SIP should contain a comprehensive emissions 

inventory for all fire emissions and a statement relating to its accuracy. It should akx~ 

identifjl whether or not fire emissions are projected to increase, decrease, or stay the 

same, and how these projections were determined. For those States with a SMP, the SIP 

should identifj its type, i.e., a basic smoke management program or an enhanced smoke 

management plan, and if the plan has been certified consistent with EPA's Interim & 

Quality Policy on Wildland and Prescribed Fire. It would also be useful to know 

specific SMP requirements for minimizing visibility impairment in Class I areas and 

classification of the various types of wildland fire (wildfire, prescribed fire, and wildland 

fire use fire) as either natural or anthropogenic. Any differences regarding the regulation 

of agricultural burning versus prescribed burning by private, State or Federd land 

managers should also be identified with discussion of the basis for any differences 

provided. 

Regional Consistency 

The Regional Planning Organizations (RPOs) have been working toward regiondlyconsistent approaches to address visibility impairment throughout the SIP development 

process. There may be circumstances when different methods were used or impairment 

assessments reached different conclusions. We understand that each State knows what 

emission control methods or air quality management strategies work best for its areas 

Each State may wish to develop strategies that are independent fiom their RPO or 

neighboring areas. 

In this context, our review of "regional consistency" will have less to do with individual 

discretion each State has in making decisions, and more on how well a group of States 

identifies and addresses similar gods for each Class I area within a common area of 

influence. 

Regional consistency can also be difficult to evaluate if neighboring SIPs (or portions of 

SIPs) are released for review at different times. It is our hope that thorough inter-State 

consultation processes will lead to consistent descriptions of apportionment and emission 

control goals, thus resulting in development of similar progress goals, regardless of 

release dates. 

Appendix J - 14
Verification and Contingencies 

Little emphasis has been placed in the RHR on verification and even less on contingency 

planning Each SIP must identify monitoring data as part of the original baseline and 

should include continued monitoring data collection and assessment as part of an ongoing 

progress review at five year intervals. Given the uncertain future of any individual 

monitoring site, the SIP should address the representativeness of both primary and 

alternative data sites. 

We encourage States to not onIy consider the need for these data to measure progress, but 

also how the plan accounts for and reconciles both unexpected and reasonably 

foreseeable emissions growth, changes to the geographic distribution of emissions, and 

substantive errors that may be found in emission inventories or other technical bases of 

the SIPs. These factors, as well as other unanticipated circumstances, may adversely 

affect your State's ability to achieve the emissions reductions projected by the SIP. 

Considering these factors through adaptive management or routine review processes may 

assist in mitigating these circumstances. 

Coordination and Consultation 

The 1999 RHR requires States to consult with the Federal Land Management agencies at 

least 60 days prior to holding any public hearing on a RHR SIP or SIP revision (40 CFR 

5 1.308(i)). Specifically, the Federal Land Manager (FLM) for the Department of the 

Interior (DOT) is the Assistant Secretary for Fish and Wildlife and Parks. However, 

assistance in the development and technical review of Regional Haze SIPs will be 

conducted by the FWS Branch of Air Quality and NPS Air Resources Division. 

To help facilitate consultation with the FLMs, each Bureau has developed a review 

strategy that includes a single point of contact for all interaction with us. For your State, 

primary DO1 contact names are: 

Tim Allen 

U.S. Fish & Wildlife Service 

Mailing Address: 

7333 W. Jefferson, Suite 375 

Lakewood, CO 80235 

Phone: 303-9 14-3 802 Fax: 303 -9 69-5444 

Email: Tim Allen@,fws. POV 

Appendix J - 15
Regional Haze State Implementation Plan Coordinatiy 

Fish & Wildlife Service and National Park Semiice-' 

August 1,2006 

This document is designed to provide you general in&ghts about U.S. Fish and Wildlife 

Service (FWS) and National Park Service (NPS) hnterests with respect to upcoming 

Regional Haze Rule (RHR) State Irnplemen~&ion Plan (SIP) development and 

consultation activities. It is not intended ti3 dictate policy or guidance. 

Baseline, Natural Condition, ad Uniform Rate 

These factors apply mainly States that have Class I areas. Other States that contribute 

to visibility impairment ia Class I areas should consider including discussion and 

conclusions on these factors in their individual plans. 

As you know, the basic calculation of baseline, natural condition, and uniform rate builds 

the fod~ation for the entire RHR SIP process. Considerable discussion and debate at the 

scieilce and policy level has occurred regarding appropriate methods to be used. As a 

consequence, several equations that include varying parameters or multipliers are 

available. Because these calculations can have a significant effect on the resulting 

progress goal, it is critical that the State provide a detailed description of the methods 

used in its SIP. If calculations include only portions of established methods or utilize 

previously undocumented or unsupported approaches, more justification should be 

included in the SIP or its supporting documentation. We encourage States to consider 

calculations that are based on equations recommended by the IMPROVE steering 

committee and that are consistent with recommended approaches fiom the appropriate 

RPO and Environmental Protection Agency (EPA) region. 

Emission Inventories 

Given the complexities associated with modern, comprehensive emission inventories, 

considerable effort should be placed on describing how these inventories were developed 

and used. We would like to see emission descriptions demonstrate an evolution that 

includes: an actual, base-year inventory used to evaluate model performance; a typical, 

base-year inventory that represents the five year, average condition which establishes 

modeled visibility impacts; and various future year, control scenarios (e.g., for required 

air pollution control programs or long term strategy measures) that demonstrate future 

visibility conditions. It would assist our review if future year inventories were clearly 

partitioned to delineate source types (by text, charts, or graphics) that are included in each 

model simulation. Improved future visibility conditions claimed in the SIP that are not 

also clearly identified in a future inventory or are not clearly included in future model 

analysis, will likely need additional and possibly considerable, attention and justification. 

One part of your emission inventory includes the implementation of "Best Available 

Retrofit Technology" (BART) on a subset of pre-Prevention of Significant Deterioration 

sources. BART source identification, elimination, and control determinations will be of 

particular interest for review. We would prefer to see a clear progression through the 

Appendix J - 16
three basic BART phases and a thorough description of the RHR prescribed factor 

analysis (if applicable). Discussions should clearly identify whether BART control levels 

apply to individual or grouped source categories. 

Area of Influence 

As you are aware, the area of influence of significant, visibility-impairing sources is an 

important SIP element. This area should clearly be identified or apportioned by State, or 

other geographic means, to encompass emission sources that contribute significant levels 

of pollutants to each Class I area as identified in your regional haze SIP. As such, these 

areas should be developed in conjunction with neighboring States and Tribes. 

Discussions of source areas of influence at both the base- and future-year levels can help 

establish a strong showing for SIP progress. States should consider the benefits of 

presenting this information in the form of transported mass by pollutant or through 

individually calculated visibility impairment indices. Using a percentage or "Top 10" 

ranking for current contributions by geographic area may not clearly describe progress 

over time. 

Reasonable Progress Goals and Long Term Strategy 

As you also know, establishing reasonable progress goals for Class I areas in your State 

andlor acknowledging reasonable progress goals for Class I areas in other States that are 

affected by emissions from your State, as well as defining associated emissions strategies 

to meet these goals, form the basis of the SIP process under the RHR. 

In developing the Long Term Strategy (LTS) required by the RHR, your State has broad 

flexibility when determining reasonable pgress goals and associated emissions. As 

noted earlier, the RHR includes a requirement for States to assess a uniform rate of 

progress and compare that rate to the reasonable progress goals set by those States with 

Class I areas. We believe that this uniform rate of progress assessment is useful in 

determining the geographic and economic extent a State should consider when 

developing the LTS associated with the reasonable progress goals. 

In general, we are looking at the degree to which the LTS is supported by RPO technical 

work and at the level of consistency among the contributing States. For Class I areas 

where the State is setting a 201 8 reasonable progress goal of equal or less impairment 

compared to the uniform rate of progress, it would assist our review to present 

information on how local, regional, and national emission strategies were emnsidered and 

applied to address visibility impairment bmken down by source category. 

For Class I areas where the reasonable progress goal is more impaired than the uniform 

rate of progress, States should consider presenting additional information on a component 

basis. Components could consist of emission source categories as before, but also 

include contributions from individual polhtants or by geographic source area. Our intent 

is to better understand where and why a strategy falls short of the uniform progress rate 

goal. Because each region has focused their emission control strategy on different 

conditions, presenting results in a component format may assist in showing what level of 

progress was made in the focus area, versus other less controllable factors. 

Appendix J - 17
Bruce Polkowsky 

National Park Service 

Mailing Address: Overnight Packages: 

NPS-ARD NPS-ARD 

P.O. Box 25287 12795 W. Alameda Parkway 

Denver, CO 80225 Lakewood, CO 80228 

Phone: 303-987-6944 Fax: 303-969-2822 

Email: Bruce Polkowsky@nps.~ov 

All questions and inquires regarding formal or informal consultation can be directed to 

these contacts. We would appreciate communications in electronic form as much as 

possible. This will allow us to quickly share appropriate documents among staff and 

between agencies. The contacts listed above will also be able to inform you of additional 

resources and information we can provide. Resource and information examples include 

progress reports, discipline experts, or implementation advice. Although the RHR places 

a strong emphasis on individual discretion in developing these plans, the NPS and FWS 

would be happy to provide more specific suggestions or information, in a form most 

useful to you, upon request. 

Appendix J - 18
JON S. CORZINE 

Governor 

DEPARTMENT OF ENVIRONMENTAL PROTECTION P -""I - - -I 

PO Box 402 E~,+ G,,,,,d, ,-. 4b--:t~, aJntrO' 

TRENTON,J 08625-0402 

TEL. # (609) 292-2885 

FAX # (609) 292-7695 LISA P. JACKSON 

Commus~oner 

January 18,2007 

Robert King. Commissiorler 

South Carolina Department of Health and Environmental Control 

2600 Bull St. 

Cclumbia, SC 29201 

Dear Mr. King, 

New Jersey is home to an area designated as a Class I area under Section 169A of the 

federal Clean Air Act, namely the Brigantine Wilderness area of the Edwin B. Forsythe National 

Wildlife Refuge. This area is one of 156 Class I areas located throughout the United States. Among 

the Class I areas in the eastern United States are the Otter Creek Wilderness area in West Virginia, 

Shenandoah National Park in Virginia, the Cape Romain Wilderness area in South Carolina and 

Acadia National Park in Maine. States with Class I areas are required to maintain and improve 

visibility in these areas to achieve natural background conditions by the year 2064. Existing 

visibility impairment in these Class I areas, also called regional haze, is caused by many sources 

located over a wide region. 

All States. regardless of whether they are home to a Class I area, must prepare a State 

Implementation Plan (SIP) for Regional Haze by December, 2007, to meet the United States 

Environmental Protection Agency (USEPA) rules implementing Section 169A of the Clean Air Act 

(40 CFR 51 ..100). This P.egiona1 Haze SIP must demonstrate that reasonable propress towards 

improved visibility at the nearby Class I area will be made by certain milestone years. The first 

milestone year is 2018. The regulations at 40 CFR 51.308 (d) (1) (iv) require States with Class I 

arzas to develop reasonable progress goals in consultation with any State that may reasonably cause 

or contribute to visibility impairment in the Class I area. This letter is part of New Jersey's 

consultation process for improving visibility at Brigantine. 

Thus we are seeking your consultation on the reasonable progress goal and development of a 

coordinated emissions management strategy. For the purpose of establishing reasonable progress 

goals for the first Regional Haze SIP, the New Jersey Department of Environmental Protection has 

identified several States that may reasonably contribute to visibility impairment at ~ri~antine~' or 

4 4 From the report entitled "Contributions to Regional Haze in the Northeast and Mid-Atlantic United States", prepared 

by NESCAUM for the Mid-Atlantic / Northeast Visibility Union (MANE-VU), August 2006. 

New Jersey Is An Equal Opporhmig Employer Printed on Recycled Paper and Recyclable 

Appendix J - 19
that are members of the Mid-Atlantic Northeast -Visibility Union (MANE-VU) planning 

organization. These States and the reason for their inclusion in our first consultation process are 

listed in the attached Table 1. 

Future regulations to control air pollutant emissions that affect visibility must be evaluated 

and included in our Regional Haze SIPS before setting this first reasonable progress goal for the 

year 201 8. To be as inclusive as possible in this important planning process, this letter is being sent 

to all States within the eastern United States. We plan to focus our initial planning efforts, and to 

jointly develop a coordinated emission management strategy to meet the first reasonable progress 

goal of this first round of SIP development, on the States identified in Table 1. 

Regardless of whether your State has been identified as causing or contributing to visibility 

impairment at the Brigantine Wilderness area, you are invited to send a representative of your State 

to future meetings to be scheduled through our respective Regional Planning Organizations. At 

these meetings, establishment of the first reasonable progress goal for the Class I areas of the 

northeastern United States will be specifically discussed. New Jersey will be working with your 

State through MANE-VU, a regional planning group formed to coordinate and facilitate the 

regional haze SIP activities. MANE-VU will also be working with other Regional Planning 

Organizations (RPOs) to which your State may belong (i.e.; the Mid-West RPO or VISTAS). 

Please send us the name, address and telephone number of the appropriate person within your 

organization to contact to inform them of the particulars of the first meeting. Please send this to 

Ray Papalski, 401 East State Street, P. 0. Box 4.18, Trenton, New Jersey 08625-041 8. 

Should your staff have any questions on this request or on the technical aspects of this letter, 

please call Ray Papalski at (609) 633-7225 or e-mail him at ray.papalski@dep.state.nj.us. Should 

you have any questions on New Jersey's plans for the consultation process, please call Mr. Chris 

Salmi of my staff at (609) 292-6710. Thank you for your anticipated cooperation, and we look 

forward to working with you and your staff in the near future. 

Sincerely yours, 

Commissioner 

Attachment 

c: Arthur Marin, NESCAUM 

Susan Weirman, MARAMA 

Chris Recchia, OTC 

Raymond Werner, USEPA 

Sandra Silva, USFWS 

Randy Moore, USDA, FS 

Chris Shaver, NPS 

Appendix J - 20
Table 1 

States to be Consulted on Establishing New Jersey's Class I Area 2018 Reasonable Progress 

Goals 

State Name (alphabetical order) Technique / Reason for inclusion2 

Connecticut 

Delaware 

District of Columbia 

Georgia 

Illinois 

Indiana 

Kentucky 

Maine 

Maryland 

Massachusetts 

Michigan 

New Hampshire 

New York 

North Carolina 

Ohio 

Pennsylvania 

Rhode Island 

South Carolina 

Tennessee 

Vermont 

Virginia 

West Virginia 

MANE-VU member 

MANE-VU member 

MANE-VU member 

0.1 ug/m3 or > 2% Sulfate Contribution 

> 0.1 ug/m3 or > 2% Sulfate Contribution . 

3 of 5 techniques (Q/D, Calpuff 1 & 2) 

> 0.1 ug/m3 or > 2% Sulfate Contribution 

MANE- W member 

4 of 5 techniques (QD, Remsad, Calpuff 1 &2) 

MANE-VU member 

> 0.1 ug/m3 or > 2% Sulfate Contribution 

MANE-VU member 

4 of 5 techniques (QD, Remsad, Calpuff 1 &2) 

4 of 5 techniques (QD, Remsad, Calpuff 1 &2) 

All techniques 

All techniques 

MANE-VU member 

> 0.1 ug/m3 or > 2% Sulfate Contribution 

> 0.1 ug/m3 or > 2% Sulfate Contribution 

MANE-VU member 

4 of 5 techniques (QID, Remsad, Calpuff 1 &2) 

All techniques 

2 From the report entitled "Contributions to Regional Haze in the Northeast and Mid-Atlantic United States", prepared 

by NESCAUM for the Mid-Atlantic 1 Northeast Visibility Union (MANE-VU), August, 2006. This table lists the 

number of techniques where a state was determined to have a greater impact on visibility levels than New Jersey 

emissions. 

Appendix J - 21
BOARD: 

Henry C. Scott 

BOARD: 

Elizabeth M. Hagood 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisner 

Secretary C. Earl Hunter, Commissioner 

Promoting andprotecting the health of the public and the environment. 

Paul C. Aughtry. 111 

Glenn A. McCal l 

Coleman F. Buckhouse, MD 

March 15,2007 

Lisa P. Jackson, Commissioner 

State of New Jersey Department of Environmental Protection 

Post Office Box 402 

Trenton, New Jersey 08625-0402 

Re: Regional Haze State Implementation Plans 

Dear Ms. Jackson: 

This letter is in response to your January 18, 2007, letter regarding effects that other state 

emissions may have on the Class I area in New Jersey known as the Brigantine 

Wilderness area (Brigantine). As you may be aware, South Carolina is a member of the 

Visibility Improvement State and Tribal Association of the Southeast (VISTAS) Regional 

Planning Organization (RPO) and is committed to improving visibility as required by 

Section 169A of the Clean Air Act. The Department is currently preparing a State 

Implementation Plan (SIP) to address visibility and regional haze issues for our own 

Class I area, the Cape Romain Wilderness area (Cape Romain). 

In your letter, you indicate that you are seeking consultation with South Carolina 

regarding the reasonable progress goal for your Regional Haze SIP. VISTAS has 

conducted assessments for the VISTAS states to help predict the influence of emissions 

from the VISTAS region on visibility at Class I areas in and near the VISTAS region. 

This work took into account the latest data and information available, including the 

reductions from Clean Air Act and state programs that will be in effect in 2018. These 

assessments do not indicate that South Carolina facility emissions have an impact on 

visibility at any Class I area outside of the VISTAS region. Therefore, we conclude that 

emissions from South Carolina do not reasonably contribute to visibility impairment at 

the Brigantine Class I area. 

SOUTH C A R O L I N A D E P A R T M E N T OF HEALTH AND ENVIRONMENTAL CONTROL 

2600 Bull Street Columbia,SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 22
Regional Haze SIPS 

Page Two 

March 15,2007 

The Department is committed to improving air quality and appreciates this opportunity 

for consultation with you and the invitation to attend future meetings of your MidAtlantic Northeast-Visibility Union (MANE-W) RPO. However, we feel that it will be 

sufficient for our VISTAS representatives to participate in the MANE-W meetings and 

to keep us informed of important developments from those meetings. 

Should you have any questions concerning South Carolina's regional haze SIP 

development, please contact Stacey Gardner of my staff at (803) 898-4287 or 

gardnesr@dhec.sc.gov. 

Sincerely, 

Robert W. King, Jr., P.E. 

Deputy Commissioner 

Environmental Quality Control 

cc: Myra Reece, Chief, Bureau of Air Quality, SCDHEC 

Robert Brown, Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Appendix J - 23
The State of New Hampshire 

DEPARTMENT OF ENVIRONMENTAL SERVJE~ CEIVED 

- -a . &?TO? ;:EAL ES 5 EiJYi2i??$.i:lr~lT:,1_ CD 

Thomas S. Burack, Commissioner 2007 APR 1 2 AH 10: 

QfFiCE 0; ilj: I:I~MH~SS~OKER April 4,2007 CHIEF OF STAFF 

CLERK OF SCOHEC BOARD 

C. Earl Hunter 

Commissioner 

SC Dept. of Health and Env. Control 

2600 Bull Street 

Columbia, SC 29201 

Dear Commissioner Hunter: 

As you are aware, New Hampshire is home to two Class I areas as designated under 

Section 169A of the U.S. federal Clean Air Act. The Great Gulf and the Presidential 

Range - Dry River Class I areas are located on the beautifid slopes of Mt. Washington, 

the highest point in the Northeastern United States. While this area is renowned fbr 

having some of the most challenging weather in the world, it also is known for providing 

very impressive vistas, that is, when visibility is not impaired by air pollution. 

Fortunately for those who visit this region and for those who live and work there, the 

Regional Haze rule requires that these areas and 154 others nationwide gradually improve 

visibility, with a goal of achieving natural conditions by 2064. While this ultimate god is' 

decades away, we begin today by taking reasonable actions and by parbering in 

consultation with states and Canadian provinces, as needed, to begin planning to take the 

first steps toward meeting this goal. I write today because we have identified your state 

or province as one that needs to be part of our collective solution to regional haze in New 

Hampshire. 

According to the Clean Air Act, all U.S. states must submit State Implementation Plans 

(SIPS) by December 2007 for regional h'aze, regardless of whether they are home to a 

Class I area. Under the Act's section 169A (including regulations at 40 CFR 5 1.300), the 

regional haze SIP must demonstrate that reasonable progress will be made at nearby 

Class I areas at 10-year intervals, beginning in 201 8. The regulations of 40 CFR 

51.308(d)(l)(iv) specify that states with Class I areas should develop reasonable progress 

goals for their Class I areas and associated measures to meet those goals, in consultation 

with any jurisdiction that may reasonably cause or contribute to visibility impairment in 

those areas. The Federal Land Managers for the Class I area are also required to be 

consulted in this process. 

While it is believed by the scientific community that every U.S. state contributes in sorue 

way to air pollution in The Great Gulf and the Presidential Range - Dry River Class I 

areas, we have limited our requests for consultations to only those states and Canadian 

providences that our analyses indicate have the potential for contributions over certain 

thresholds for PM2.5 and/or sulfate to regional haze in our Class I areas. Beyond this, we 

are asking all states within our own Regional Planning Organization, the Mid-Atlantic 

DES Web site: www.des.nh.gov - 

P.O. Box 95,29 Hazen Drive, Concord, New Hampshire (93302-0095 

Telephone: (603) 271-1370 Fax: (603) 271-1381 TDD Access: Relaw NH 1 -8n0-7?<-7o64 

Appendix J - 24
Northeast - Visibility Union (MANE-VU) to consult with us. Because we have asked 

you to join us in consultation does not necessarily imply that we will be asking for air 

pollution control beyond measures you may have already identified as necessary for your 

own state for ozone and PM2.5 ambient air standard attainment. By joining us, you can 

help us shape ourregional haze progress goals for 201 8 and help play a part in 

determining the best way to meet those goals for the New Hampshire Class I areas. 

We, or a representative fiom MANE-VU, will be contacting you soon to arrange a 

consultation meeting. Thank you for your anticipated participation in this consultation 

and we look forward to working with you and your staff. Should you have any questions, 

please contact Jeff Underhill of my staff at 603-271-1370 (or email: 

junderhill@des.state.nh.us). 

Sincerely Yours, 

Thomas S. Burack 

Commissioner 

cc: Robert Scott, NHDES Air Resources Division 

JefEey Underhill, NHDES Air Resources Division 

Anna Garcia, OTC 

Arthu Marin, NESCAUM 

Susan Weirman, MARAMA 

Appendix J - 25
BOARD: 

Elizabeth M. Hagood 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisner 

Secretary 

PROMOTE PROTECT PROSPER 

C. Earl Hunter, Commissioner 

Promoting andprotecting the health of the public and the environment. 

BOARD: 

Henry C. Scott 

Paul C. Aughtry, 111 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

June 29,2007 

Thomas S. Burack, Commissioner 

State of New Hampshire Department of Environmental Services 

Post Office Box 95 

Concord, New Hampshire 03302-0095 

Re: Regional Haze State Implementation Plans 

Dear Mr. Burack: 

This letter is in response to your April 4, 2007, letter regarding effects that other state 

emissions may have on the Class I areas in New Hampshire known as the Great Gulf 

Wilderness Area and the Presidential Range - Dry River Wilderness Area. As you may 

be aware, South Carolina is a member of the Visibility Improvement State and Tribal 

Association of the Southeast (VISTAS) Regional Planning Organization (RPO) and is 

committed to improving visibility as required by Section 169A of the Clean Air Act. The 

Department is currently preparing a State Implementation Plan (SIP) to address visibility 

and regional haze issues for our own Class I area, the Cape Romain Wilderness Area. 

In your letter, you indicate that you are seeking consultation with South Carolina 

regarding the reasonable progress goal for your Regional Haze SIP. VISTAS recently 

conducted an analysis for the VISTAS states to help predict the influence of emissions 

from the VISTAS region on visibility at Class I areas in and near the VISTAS region. 

This work took into account the latest data and information available, including the 

reductions from the Clean Air Act and state programs that will be in effect in 2018. 

These assessments do not indicate that South Carolina facility emissions have an effect 

on visibility at any Class I area outside of the VISTAS region. Therefore, we conclude 

that emissions from South Carolina do not reasonably contribute to visibility impairment 

in the New Hampshire Class I areas. 

The Department is committed to improving air quality and appreciates this opportunity 

for consultation with you and your invitation to attend future meetings of your MidAtlantic Northeast-Visibility Union (MANE-VU) RPO. We understand that upcoming 

meetings between the VISTAS and MANE-VU RPOs are being scheduled; as such, we 

intend to consult with your state through our VISTAS representatives at these meetings. 

SOUTH CAROLINA DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhecgov 

Appendix J - 26
Mr. Thomas S. Burack 

June 29,2007 

Page 2 

Should you have any fbrther questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

masonmr@,dhec.sc.gov. 

~dbert W. King, Jr., P.E. 

Deputy Commissioner 

Environmental Quality Control 

cc: Myra Reece, Chief, Bureau of Air Quality, SCDHEC 

Robert J. Brown, Jr., Director, Division of Air Planning, Development and 

Outreach, SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Appendix J - 27
, April 9, 2007 

Georgia Department of Natural Resources 

Environmental Protection Division Air Protection Branch 

his. Myra Reece 

SC - Dept of Health ant1 !?:?\I i'ontrol 

Bureau of Air Quality 

2600 Bull St 

Columbia SC 2920 1 - 1 797 

Re: Four Factor Analysis for Regional Haze 

4244 International Parkway Suite 120 Atlanta Georgia 30354 

4041363-7000 Fax: 4041363-71 00 

Noel Holcomb, Commissioner 

Carol A Couch, Ph.D., Pirector 

BUREAU OF AIR QUALITY 

Dear Ms. Reece: 

Under the Environmenral Protectioil Agency's Kegional Haze Kule (citation), the Georgia 

i?n\ironmen~ai-'rorecrion :nus1 submii ro EPw a Sbace In:piern~.i~~a~i~n pian (SiF) ~hal t-siaklisr~\~> 

reasonable progress towards achievjng natural visibility ~r~nditiom. Inorder to achieve this 

unifbrm rate of progress. EPII musi establish reasonable yrogrzss xoals through emissions 

reductions defined in the state's SIP submittal. 

Section 169A(g)(l) of the CAA and Section 5 1.308(d)(l)(i)(A) of the Regional Haze Rule decm~ 

that States must consider four "statutory factors" in consultatiu~l \~.ith other affected States, 

Federal Land Managers. and all stakeholders. in determining thcir reasonable progress goals. 

These following four qtz~utory fbcfor? are: 

a) The costs of compliance, 

b) The time necessary for compliance, 

c) The energy and non air quality environmental impacts oi'compliance, aid 

d) The remaining useful life of existing sources that coiltribute to visibility impairment. 

An analysis of wind trajectory residence times, 20 18 SO2 emission pro-jections, and distance 

frorl nearby Class I areas allowed EPD to identify sources likely to contribute more than 0.5% to 

the total visibility impairment caused by sulfate at nearby Class I areas in 201 8. Based on this 

~IIUI~X~, a ,7,,, t-.. -:I:!: .-- :- Ti,..-.-:.- -.-A -+-;mh5cr:z- ot?+-c h2~/.2 k.cty: :dq!?r5<d h\. E!)g zp ~IUI~~II'L> Lh~~.A~nb~ ,LA ubLv:c a u,~u .LbAb~L.. . "LLLLu .' J 

sources which signiiicantly impact orie or more Class I areas in Georgia. S~rlce Coliut1,a 

Wilderness and other nearby Class I areas are clearly meeting the uniform rate of progress glide 

slope according to VISTAS modeling, only lion-EGUs impacting these Class I area were 

included on the list. Since the Class I areas in Southern Georgia and Northern Florida (e.g. 

Okefenokee, Wolf Island, St. Marks) are not clearly meeting the uniform rate of progress glide 

slope according to VIS?'AS modeling, both EGlis and non-EGlJs impacting these Class 1 area 

were irlclclcled on the list. 

Appendix J - 28
I Myra Reece 

April 9,2007 

. Page two 

The sources in Georgia that are contained in this list include: 

GEORGIA PACIFIC CORPORATION, CEDAR SPRIN - UNIT R402 

GEORGIA PACIFIC CORPORATION, CEDAR SPRIN - UNIT U500 

GEORGIA PACIFIC CORPORATION, CEDAR SPRIN - UNIT U501 

GEORGIA POWER COMPANY, MITCHELL STEAM-EL - UNIT SG03 

GEORGIA-PACIFIC BRUNSWICK OPERATIONS - UNIT F1 

GEORGIA-PACIFIC BRUNSWICK OPERATIONS - UNIT M24 

GEORGIA-PACIFIC CORP SAVANNAH RIVER MILL - UNIT BOO 1 

GEORGTA-PAC!Fl(' PORP CAVAhVAF! RIVFR MTT,! - 1 Th. TT !3?07 

GEORGIA-PACIFIC CORP SAVANNAH RIVER MILL - 1 TNIT BOO3 

INLAND PAPERBOARD & PACKAGING, INC. - UNIT F4 

INTERNATIONAL PAPER - SAVANNAH MILL - CTNIT PR 13 

INTERSTATE PAPER LLC - UNIT F1 

JESCTP MILL, RAYONIER PERFORMANCE FIBERS - CTNIT PB02 

JESCTP MILL, RAYONIER PERFORMANCE FIBERS - UNIT PB03 

JESUP MILL, RAYONIER PERFORMANCE FIRERS - ITNIT RFOl 

JESCTP MILL, RAYONIER PERFORMANCE FIRERS - UNIT RF04 

MILLER BEWING CO - UNIT ROOl 

MILLER BREWING CO - UNlT BOO2 

MOUNT VERNON MTLLS. TNC , APPAREL FABRIC - IJNIT EIJ03 

MOUNT VERNON MILLS, INC., APPAREL FABRIC - UNIT EU04 

PACKAGING CORPORATION OF AMERICA - VALDO - LW1T 101 7 

SAVANNAH ELECTRIC: KRAFT STEAM - ELECTRI - UNIT SGOl 

SAVANNAH ELECTRIC: KRAFT STEAM - ELECTRT - UNIT SG02 

SAVANNAH ELECTRIC: KRAFT STEAM - ELECTRI - UNIT SG03 

SAVANNAH ELECTRIC: MCINTOSH STEAM - ELEC - UNIT SGOl 

SAVANN.4H SUGAR REFINERY - I JNIT U161 

SOUTHERN STATES PHOSPIIATE & FERTILIZER C - UNIT SA02 

The sources in Florida that are contained in this list include: 

ANCHOR GLASS CONTA41NER CORPORATION - UNIT 3 

ANCHOR GLASS CONTAINER CORPORATION - UNIT 4 

GEORGIA-PACIFIC COW. PULPIPAPER MILL - UNIT 15 

GEORGIA-PACIFIC CORP. PULPIPAPER MILL - IJIVIT 16 

IFF CHEMICAL HOLDINGS, INC. - UNIT 3 

JEFFERSON SMURFIT CORPORATION (I JS) - UNIT 15 

JEFFERSON SMURFIT CORPOR4TION (US) - UNIT 6 

MILLENNIUM SPECIALTY CHEMICALS - UNlT 5 

MILLENNIUM SPECIALTY CHEMICALS - UNIT 6 

Appendix J - 29
I Myra Reece 

April 9, 2007 

Page three 

PROGRESS ENERGY FLORIDA, INC. CRYSTAI, RI - UNIT 1 

PROGRESS ENERGY FLORIDA, INC. CRYSTAL R1- lJNIT 2 

RAYONIER PERFORMANCE FIRERS LLC - LNIT 6 

SAINT JOHNS RIVER - UNIT 16 

SAINT JOHNS RIVER - UNIT 17 

SEMINOLE ELECTRIC COOPERATIVE, INC.- UNIT 1 

SEMINOLE ELECTRIC COOPERATIVE, INC. - UNIT 2 

WHITE SPRINGS AGRICULTURAL CHEMICALS, INC - UNIT 66 

WHITE SPRINGS AGRICULTURAL CHEMICALS, INC - UNIT 67 

The sources in South Carolina that are contained in this list include: 

GIANT CEMENT CO - LNIT 005 

H0LCIM:HOLLY HILL - UNIT 002 

MEADWESTVACO CORPORATION INC - LJNIT 006 

SANTEE COOPER CROSS - LTNIT 002 

SANTEE COOPER CROSS - UNIT 3 

SAIVTEE COOPER JEFFERIES - UNIT 003 

SANTEE COOPER JEFFERIES - UNIT 004 

SCE&G:CANADYS - UNIT 001 

SCE&G:CANADYS - UNIT 002 

The sources in Tennessee (non-EGU only) that are contained in this list include: 

A.E. STALEY MANUFACTURING COMPANY - UNIT 005 

ALUMINT JM COMPANY OF AMERICA - SOUTH PLAN - UNIT 16 

ALUkllN liM cOMl'k~\l k Oi. F. lvlEK, CA - S UL, i ki PLXru - Uiu 1 i i 'I 

BOWATER NEWSPRINT & DIRECTORY - CALHOUN - UNIT 01 5 

E. I. DU PONT DE NEMOURS AND COMPANY - UNIT 0002 

EASTMAN CHEMICAL COMPANY - UNIT 021 520 

INTERTRADE HOLDINGS, INC. - UNIT 001 

U.S. DEPARTMENT OF ENERGY, Y- 12 PLANT - UNIT 002 

The Georgia facilities on this list have been sent letters requesting that they perform a Four 

Factor Analysis and submit their report to us by May 3 1, 2007. We would like for you to 

consider adding your state's facilities listed above to your state's final "Four Factor Analysis" list 

of facilities. In addition, we would very much appreciate a copy of your final "Four Factor 

Analysis" list of facilities when it is ready. 

Appendix J - 30
. Myra Reece 

April 9, 2007 

Page four 

If you have any questions or need more information, please contact Jimmy Johnston at (404) 

363-7014 or via email at jimmyjohnston@dnr.state.ga.us. 

Sincerely, 

(?&.CL4-L. t, $A\, 3 -, a/ fG-3 

Heather Abrams 

Chief 

Air Protection Branch 

c: Jiminy Johnston, CiA EPD 

James Kelly, GA EPD 

James Boylan, GA EPD 

Elisabeth Munsey, GA EPD 

John Glass, SC DHEC 

Pat Brewer, VISTAS 

Appendix J - 31
BOARD: 

Elizabeth M. Hagood 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman PROMOTE PROTECT PROSPER 

Steven G. Kisner 

Secretary C. Earl Hunter, Commissioner 

Promoting andprotecting the health of the public and the environment. 

June 29,2007 

BOARD: 

Henry C. Scott 

Paul C. Aughtry, 111 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

Heather Abrarns, Chief 

Georgia Department of Natural Resources 

Environmental Protection Division, Air Protection Branch 

4244 International Parkway, Suite 120 

Atlanta, Georgia, 30354 

Re: Regional Haze State Implementation Plans 

Dear Ms. Abrarns: 

This letter is in response to your April 9, 2007, letter regarding the four factor analysis 

done in association with the Georgia Regional Haze State Implementation Plan. 

South Carolina is also preparing a State Implementation Plan (SIP) to address visibility 

and regional haze issues for our own Class I Federal area, the Cape Romain Wilderness 

area (Cape Romain). 

As your letter indicated, both the Department and the Georgia Environmental Protection 

Division (EPD), in developing their Regional Haze SIPS, must establish reasonable 

progress goals. In developing these goals, both the Department and EPD should consider 

four "statutory factors," including the cost of compliance, the time necessary for 

compliance; the energy and non air quality environmental impacts of compliance, and the 

remaining useful life of existing sources that contribute to visibility impairment. 

Your letter referenced several facilities in Georgia and neighboring states "likely to 

contribute more than 0.5% to the total visibility impairment caused by sulfate at nearby 

Class 1 areas in 201 8." Further, the EPD requested that the Department consider adding 

the following South Carolina facilities to our own SIP'S "Four Factor Analysis" list: 

Giant Cement Co - Unit 005 

Holcim: Holly Hill - Unit 002 

Meadwestvaco Corporation Inc - Unit 006 

Santee Cooper Cross - Unit 002 

Santee Cooper Cross - Unit 003 

Santee Cooper Jefferies - Unit 003 

Santee Cooper Jefferies - Unit 004 

SCE&G: Canadys - Unit 00 1 

SCE&G: Canadys - Unit 002 

SOUTH CAROLINA DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL 

26q0 Bull Street Columbia, SC29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 32
Ms. Heather Abrams 

June 29,2007 

Page 2 

The Department, in establishing reasonable progress goals required by the Regional Haze 

Rule, has identified the following sources as contributing to visibility impairment in 

South Carolina: 

EGU Sources 

SCE&G: CANADYS, Colleton Co. 

SANTEE COOPER JEFFERIES, Berkeley Co. 

SANTEE COOPER CROSS, Berkeley Co. 

Non-EGU Sources 

INTERNATIONAL PAPER: GEORGETOWN, Georgetown Co. 

GIANT CEMENT CO, Dorchester Co. 

Although these facilities may cause or contribute to visibility impairment in Georgia and 

South Carolina, firther analysis indicates that for several of these sources either the cost 

of compliance is prohibitive or the facility's relative contribution to visibility impairment 

is below the aforementioned threshold of 0.5%. This is true for Giant Cement, 

International Paper, Holcim, and Meadwestvaco. 

SCE&G and Santee Cooper (Cross and Jeffries) are EGUs subject to CAIWCAMR. 

CAIR will permanently cap emissions of SOz and NO, in the eastern United States. 

~hei fully implemented, CAIR will reduce SO2 emissions in these states by over 70 

percent and NOx emissions by over 60 percent from 2003 levels. CAMR will reduce 

utility emissions of mercury from 48 tons a year to 15 tons, a reduction of nearly 70 

percent. Moreover, Santee Cooper's analysis of its Cross facility shows that 

current/planned controls are sufficient to reduce its facility's contribution to visibility 

impairment below the aforementioned threshold amount of 0.5%. Additionally, a 2004 

Consent Decree with Santee Cooper Jefferies demonstrates that it is not feasible to 

further control its emissions. SCE&G and Santee Cooper (Cross and Jeffries) will 

closely monitor emissions to account for projected future growth and thereby may 

implement future controls as deemed necessary by CAIWCAMR. 

The Department is continuing to communicate with Santee Cooper, SCE&G, and 

International Paper and is currently awaiting additional information in order to complete 

its four factor analysis for each of the aforementioned facilities. As additional 

information becomes available, we will provide this information to you. 

The Department is committed to improving air quality and appreciates this opportunity 

for consultation with you. 

Appendix J - 33
Ms. Heather Abrams 

June 29,2007 

Page 3 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

masonmr@,dhec.sc. aov. 

Sincerely, 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and 

Outreach, SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Appendix J - 34
VISTAS State Consultation Meeting 

Federal Land Managers and Environmental Protection Agency 

Asheville, North Carolina 

June 12, 2007 

Attendees/Affiliation

Tim Allen, FWS Cindy Huber, FS 

Diana Andrews, KY Bill Jackson, FS 

Julie Aslinger, TN Brenda Johnson, EPA Region 4 

Vivian Aucoin, LA Jimmy Johnston, GA 

Leigh Bacon, AL Rhea Jones, EPA OAQPS 

Tom Ballou, VA Kathy Kaufman, NC 

Elliott Bickerstaff, MS Martin Luther, KY 

Laura Boothe, NC Tim Martin, AL 

Jim Boylan, GA Doris McLeod, VA 

Lona Brewer, KY Ann Mebane, FS 

Pat Brewer, VISTAS Brock Nicholson, NC 

Joelle Burleson, NC Michele Notarianni, EPA OAQPS 

Bob Carson, NPS Bruce Polkowsky, NPS 

Catherine Collins, FWS Jim Renfro, NPS 

Fred Durham, WV Tom Rogers, FL 

Stacey Gardner, SC Renee Shealy, SC 

Rick Gillam, EPA Region 4 Don Shepherd, NPS 

John Glass, SC Andrea Stacy, FS 

Janice Godfrey, NC Barry Stephens, TN 

Todd Hawes, EPA OAQPS Bob Stroik, NPS 

Sheila Holman, NC Ming Xie, NC 

John Hornback, Metro4/SESARM 

Chris Howard, AL 

Objectives

The purpose of this consultation meeting was to overview the VISTAS and state 

technical analyses that will be the basis of the state implementation plans for regional 

haze and to receive feedback from the Federal Land Managers (FLM) and the 

Environmental Protection Agency (EPA) on the presented materials. 

Expectations

The meeting opened with participants stating their expectations for consultation. 

FLM interests included: 

• understanding VISTAS technical analyses and how states will use these analyses 

in SIPs 

Appendix J - 35
• understanding states’ reasonable progress goals and having opportunity to consult 

on these goals 

• states’ plans for consultation with neighboring states 

• states’ plans for mid-course review 

• states’ plans for continued consultation with FLM 

EPA interests included: 

• learn how states are using technical analyses 

• understand FLMs positions 

• provide clarification of revised reasonable progress guidance 

• observe and report outstanding issues to management 

States interests included: 

• feedback from the FLM and EPA if technical analyses, when completed, would

meet FLM and EPA expectations for SIP documentation. 

• Some states would like to consider this meeting to meet the requirement for a face 

to face meeting with FLM, with further follow up and discussions by conference 

call. 

• Common understanding between states, FLM, and EPA of revised reasonable 

progress guidance 

• This first SIP for regional haze will be a learning experience. States can use midcourse review to evaluate what is working and where revisions are needed. 

Technical Analysis Summary

Pat Brewer summarized the VISTAS Technical Analyses (see presentation on 

VISTAS website, http://www.vistas-sesarm.org/documents/FinalDocs.asp). 

Ammonium sulfate is the primary contributor to haze at the VISTAS Class I areas. 

Emissions sensitivity analyses showed greatest visibility benefit from reducing SO2 

from electric utilities or industrial point sources and little benefit from reducing NOx, 

anthropogenic VOC, or primary sources of carbon. Ninety-six percent of the SO2 

emissions in the VISTAS states are from electric utility or industrial point sources. 

SO2 Areas of Influence were defined for each Class I area. In 2018 coal fired electric 

utility boilers and coal fired industrial boilers are the largest SO2 emission categories 

in every SO2 Area of Influence. Several other industrial categories were minor 

contributors to SO2 emissions in the Areas of Influence. Control options and costs of 

controls were provided to the states. 

Concurrent Consultative Sessions

The meeting then broke into two concurrent sessions addressing the mountain or 

coastal Class I areas. Each state then summarized: 

• criteria used to rank sources in SO2 Areas of Influence for Class I areas in that state 

• list of sources for which reasonable control measures and 4 statutory factors are 

being considered 

Appendix J - 36
• expected controls from exiting regulations for listed sources 

• status of BART determination 

• plans for consultation with neighboring states 

• next steps 

Groupings for of Class I Areas for VISTAS and Surrounding Regions

.

.

.

.

Hercules 

Glade, 

MO .

.

VISTAS Class I Areas

Mountains Groupings

1. Great Smoky Mtns (5 sites)

2. Mammoth Cave

3. Sipsey

4. Shenandoah (4 sites)

Coastal Groupings

5. Swanquarter

6. Cape Romain 

7. Okefenofee (4 sites)

8. Everglades

Neighboring Sites

9. Breton

10.Mingo (4 sites)

11.Brigantine

.

.

.

.

Hercules 

Glade, 

MO .

.

VISTAS Class I Areas

.

.

.

.

Hercules 

Glade, 

MO .

.

VISTAS Class I Areas

Mountains Groupings

1. Great Smoky Mtns (5 sites)

2. Mammoth Cave

3. Sipsey

4. Shenandoah (4 sites)

Coastal Groupings

5. Swanquarter

6. Cape Romain 

7. Okefenofee (4 sites)

8. Everglades

Neighboring Sites

9. Breton

10.Mingo (4 sites)

11.Brigantine

Status of BART Determinations in Each State

BART control for some sources subject to BART may be fuel switching

Some BART subject facilities took limits to exempt out, these are not included as a control

Alabama NO 31 2 2

*listed individual units, may or may not be the same facility

W.Virginia NO 22 3 0

Florida NO 47 9 don't know

Kentucky NO 31 1 1 maybe

Mississippi NO 15 2 1

N. Carolina NO 17 2 0

S. Carolina NO 21 14 0

Virginia NO 13 3 3*

Georgia NO 25 3 1 or 2

Tennessee NO 13 4 1 or 2

STATE Complete Eligible Subject Controlled

BART control for some sources subject to BART may be fuel switching

Some BART subject facilities took limits to exempt out, these are not included as a control

Alabama NO 31 2 2

*listed individual units, may or may not be the same facility

W.Virginia NO 22 3 0

Florida NO 47 9 don't know

Kentucky NO 31 1 1 maybe

Mississippi NO 15 2 1

N. Carolina NO 17 2 0

S. Carolina NO 21 14 0

Virginia NO 13 3 3*

Georgia NO 25 3 1 or 2

Tennessee NO 13 4 1 or 2

STATE Complete Eligible Subject Controlled

Appendix J - 37
Issues Discussed and Resolved

 

• Reasonable progress goal should be reported using deciview with one significant 

digit beyond the decimal point (e.g. 25.4 dv, not 25.44 dv). 

• Final long-term strategy (LTS) run will not be completed in time for FLM 

consultation prior to public review. States can report that reasonable progress goal 

for 20% worst days will be at least as stringent as BaseG2a modeling results and 

that additional BART and reasonable measures within the state and neighboring 

states could accomplish greater progress than the Base G2. The final RPG would 

be reflected in the RH SIP submittal. 

• Consultation with non-VISTAS states: AR and MO are consulting with KY and 

TN. LA is participating in VISTAS meetings as consultation for BRET. MANEVU states have asked VISTAS states to consult this summer (call in July, meeting 

in Aug). 

• All four statutory factors need to be considered, but if there are no cost effective 

controls for a source, then the other three factors do not need to be addressed in 

depth. 

• GA found that 2018 emissions for non-EGU sources were sometimes 

overestimated, likely due to overestimating growth factors. 

• SIP wording should note that sources that take emissions limits to exempt from 

BART cannot go above that limit in the future. 

Issues Requiring Follow-up

• FLM asked KY about their plans to consult with MRPO states re impacts on 

Mammoth Cave 

• FLM and EPA asked for justification of the Class I area groupings. The 

groupings were intended to organize presentation of data for similar sites. The 

groupings are based on similar Areas of Influence and similar responses to 

geographic sensitivity analyses. 

• Most states used emissions divided by distance (Q/d) and maximum residence 

time (RTmax) to rank sources in the SO2 Areas of Influence. Most states used a 

1% contribution as cutoff to consider a source for 4 factor analysis of reasonable 

further controls. GA used 0.5% contribution as cut off. FLM and EPA asked for 

justification of cutoff value that states selected. FLM also suggested that states 

consider if a source affects more than one Class I area. 

• FLM need follow up from states on BART controls under review. 

• FLM would like to help define what midcourse review will look like. Focus 

expected to be on emissions changes from baseline to 2012 (CAIR, CSA, BART, 

projected mobile reductions). Trends in monitoring data may also be considered 

but may be difficult to interpret due to inter-annual variability in meteorology. 

What commitments will states make if emissions reductions are less than 

projected in the SIP? Need to describe in SIP how States will check progress and 

make corrections if/as needed. 

Appendix J - 38
• SIP narratives need wording about new source growth and how PSD permitting 

will be affected, as well as about uncertainty in the 2018 projections. Each SIP 

must commit to what will be specifically reviewed at the 5-year check. Would 

like to see specific procedures on consulting with FLM. 

• FLM also suggested that States should interrelate PSD and haze by having the 

haze SIP set a zone around each Class I area to point out to state PSD permitters 

the area where they need to look more critically at controlling growth to protect 

the Air Quality Related Values (AQRVs) 

• Don’t forget deposition data, what improvements in deposition projected? Bill 

Jackson will make available upon request deposition results for 12 km grid using 

2018 Base G emissions (provided by Bill by Alpine Geophysics). 

• Consider benefits from ozone and PM2.5 attainment. How will new ozone 

standard affect visibility?

• Florida needs to discuss with EPA Region 4 its plans for setting reasonable 

progress process. 

• FLM would prefer that they get a copy of the SIPs 60 days prior to the public 

hearing. 

• If states are not going to meet the December 17, 2007 deadline, they need to let 

EPA know and work with them. 

• Since Breton is not meeting the uniform rate of progress glidepath, FLM 

suggested that emissions sources permitted by Mineral Management Services 

should be separated from domestic sources (this has not been done to date). FLM 

also suggested that LA alert EPA that there is a marine treaty issue with MMS 

permits. 

• For Class I areas impacted by sources in different RPOs, it would be helpful if 

states used consistent methods for weight of evidence and reasonable progress 

goals. For BRET, LA could do similar AoI analysis for sources as VISTAS 

states. 

• Setting RPG for 20% best days: do states set as no degradation from 2000-2004 

baseline or as modeled results for 20% best days in 2018? In follow up with EPA 

and FLM: rule states no degradation on the 20% best days but also says that can’t 

set goal worse than progress expected under implementation of controls under 

other CAA programs. If Base G2 model results project that 20% best days will be 

better in 2018 than in 2000-2004, then states should discuss this is setting goal for 

20% best days. FLM pointed out if states use model results for 20% worst days, 

they should also use model results for 20% best days. States’ concern is whether 

model performance for 20% best days is reliable since most of VISTAS model 

performance evaluation to date has focused on 20% worst days, not 20% best 

days. For instance, there are issues with poor nitrate performance issues on 

winter days that could affect model projections for nitrate in 2018 for 20% best 

days that occur in the winter. 

Appendix J - 39
Discussion of Revised Regional Haze Guidance

• EPA cautioned that states need to be careful to interpret the guidance as a whole 

and not isolate any single sentence in the guidance out of context of the whole 

document. The guidance does not trump the Regional Haze Rule or the Clean Air 

Act. 

• States need to look at the four statutory factors to determine what measures are 

reasonable. 

• States have flexibility. The new guidance states that in deciding the minimum 

RPG it is reasonable to defer reductions to later planning periods in order to 

maintain a consistent glidepath toward the long-term goal. 

• One possible approach is to use uniform reasonable progress to back out what 

additional controls are necessary. 

• $/dv approach is included in the new guidance as an additional measure of cost 

effectiveness. It is not intended to be used instead of $/ton. VISTAS does not 

have plans to generate $/dv in response to new guidance. If used, the correct 

metric for this objective would be $/Mm-1 rather than $/dv because dv is 

logarithmic. 

Conclusions and Plan of Action

VISTAS states committed to share summary of the meeting with the VISTAS 

workgroups. FLM, EPA, and VISTAS workgroups are asked to review the Technical 

Summary that is posted on the VISTAS website and provide feedback if the format, 

when completed, would meet expectations for a SIP Narrative. Comments are 

requested by the July 23 workgroup call. 

VISTAS contractors are working on final project reports. Reports will be posted to 

the VISTAS website. States are working on documentation for SIPs and intend to 

provide documentation to FLM for formal review prior to the public hearings. NC 

and SC are looking to provide documentation in July; other states expect 

documentation to be ready in the Aug-Nov timeframe. Each state will independently 

set their FLM consultation, public review, and SIP submittal process. 

VISTAS states are consulting with neighboring states as appropriate to meet the

regional haze rule requirements. Each state is defining its own consultation process. 

VISTAS states are not clear if a final meeting with the VISTAS workgroups is 

needed prior to the public review. States have been working directly with their 

sources as necessary to evaluate BART controls and reasonable further control 

measures. VISTAS is providing technical support to the States, but the States are not 

developing collective policy recommendations through VISTAS. 

Questions should be directed to John Hornback, Pat Brewer, or state contacts. 

Appendix J - 40
July 10,2007 . -- 

OZONE 

T R A p~ s p 0 R T C. Earl Hunter 

C 0 M M I S S I 0 N South Carolina Department of Health & 

Environmental Control 

2600 Bull Street 

Columbia, SC 29201 

Connecticut 

ECEOVE 

BUREAU OF AIR QUALITY 

Delaware Dear Mr. Hunter, 

District of Columbia 

On behalf of New Jersey, New Hampshire, Vermont, and Maine, the 

Mid-Atlantic/Northeast Visibility Union (MANE-VU) States with Class I 

arezs, I am pleased to invite you to our upcoming State-to-State consultation 

Maine call and meetings. We are holding these events in order to comply with the 

consultation requirements specified in 40 CFR, Part 51, and in accordance 

Maryland with the Inter-RPO Consultation Framework that MANE-VU approved at its 

May 5,2005 Board Meeting. 

Massachusetts Our goal for these and future consultation calls and meetings is to help 

states exchange and understand information regarding visibility issues in 

New Hampshire MANE-W Class I areas, and to facilitate States' working together to develop 

acceptable approaches and policies for improving visibility. 

New Jersey After reviewing technical analyses the MANE-W Class I states have 

formulated some ideas on the types and amounts of emissions reductions that 

New ~ork are reasonable and, therefore, necessary to achieve reasonable progress in 

improving visibility at MANE-VU Clzss I areas. Due to the downwind 

Pennsylvania location of MANE-VU Class I areas, these emissions reductions would be 

from states both within and outside the MANE-VU region. We know that you 

have also been working hard to address the visibility issues facing your own 

Rhode Island region's Class I areas. The consultation calls ar.d meetings we engage in over 

the next several weeks will allow us to compare our work and findings, 

Vermont discuss what adjustments may be appropriate, and provide an opportunity to 

develop mutually beneficial solutions. 

Virginia 

MANE-VU has been working closely with the Visibility Improvement 

State and Tribal Association of the Southeast (VISTAS) to find mutually 

Christopher Recchia convenient dates and times for these events, and we hope that you will be able 

Executive Director to participate in these discussions. The schedule of calls and meetings that 

have been planned are as follows: 

444 N. Capitol St. NW 

Suite 638 Open Technical Call on July 19, 2007 from 10 am - 12:30 pm EDT 

Washington, DC 2000 I (call-in number 1-866-537-1 634, passcode 7545482#); and 

(202) 508-3840 

FAX (202) 508-3841 

e-mail: ozone@otcair.org 

Appendix J - 41
In-person Consultation Meeting on August 20,2007 in Atlanta, GA 

from 10:OO am - 3:30 pm EDT. - - 

- -- 

The purpose of the Open Technical Call on July lgth is to provide a 

forum for Statedstaff from all three RPOs to summarize their technical 

analyses and findings, and to discuss the initial ideas on the types and amounts 

of reductions that may be needed to achieve reasonable progress. The call is 

open to all States and Tribes in the MANE-W, VISTAS and MRPO regions, 

and open to all levels of participation (Commissioner/ Secretary, Air Director 

and staff), as well as to representatives from the U.S. Environmental 

Protection Agency and the Federal Land Manager agencies. 

The purpose of the in-person Consultation Meeting on August 20th is 

to have State-to-State policy discussions based on the technical analyses and 

findings presented during the Open Technical Call. We anticipate that at this 

meeting we will go into greater depth in our discussion of the types of actions 

and reductions necessary to achieve reasonable progress, in accordance with 

the requirements of the Regional Haze Rule. The meeting is open to all States 

and tribes in the MANE-W and VISTAS regions, as well as to 

representatives from the U.S. Environmental Protection Agency and the 

Federal Land Manager agencies. We welcome all levels of State and Tribal 

participation, but it will be particularly important to have decision-makers in 

attendance who can engage in meaningful discussions with other States and 

Tribes on policies and solutions to the visibility issues affecting the Class I 

areas. 

As both the Open Technical Call and the in-person Consultation 

Meeting are government-to-government transactions, stakeholders are not to 

participate. 

Attached are draft agendas for the Open Technical Call and the inperson Consultation Meeting. We are circulating these drafts for your review 

and comment, and will work with VISTAS to revise as necessary to facilitate 

our discussions. 

In addition, attached is the draft table of contents for a briefing book 

which will contain summaries of the technical analyses and work that MANEVU has performed. We will be developing these briefing books and getting 

them to you in advance for your use during the Open Technical Call and 

Consultation Meeting. 

Finally, we are attaching a copy of four actions recently approved by 

MANE-VU. The first is a Resolution by the MANE-W States with Class I 

areas outlining the principles they will follow in implementing the Regional 

Haze Rule. The second is a Statement that lays out a course of action that 

MANE-VU, as a region, will pursue toward assuring reasonable progress. 

Appendix J - 42
The third is a Statement that outlines the MANE-W States' initial request for -. a course of action by States outside of-the%ANETt-fegir)n tow-muring 

reasonable progress at our Class I areas. The course of action described is 

intended as a starting point for our discussions, and will be examined in light 

of the technical work and findings provided by or on behalf of the affected 

States during the Open Technical Call and the in-person Consultation 

Meeting. The fourth of these attachments is a request that we are making of 

the U.S. Environmental Protection Agency to work with the eastern Regional 

Planning Organizations to develop a national proposal to achieve additional 

cost-effective SO2 reductions. MANE-VU would welcome support fiom 

other RPOs for this request for EPA action. 

Please contact me if you have any questions about the scheduling or 

logistics of the call or meeting, or generally about the consultation process. 

On behalf of the MANE-W States, I look forward to working with you and 

VISTAS to develop an informative and productive consultation process of that 

yields mutually beneficial results. 

Sincerely, 

Anna Garcia 

Acting Executive Director 

Cc: Myra C. Rezce, South Carolina DHEC 

Renee Shealy, South Carolina DHEC 

Enclosures 

Appendix J - 43
North Carolina Department of Environment and Natural Resources 

Michael F. Easley, Governor . Ross, Jr., Secretary 

ercash, P.E., Directa 

Ms. Myra Reece, Chief 

South Carolina Department of Health and Environmental Control, Bureau of Air Quality 

2600 Bull Street 

Columbia, South Carolina 2920 1 

Dear Ms. Reece: 

This letter is to discuss consultation between our states on reasonable progress under the 

Regional Haze Rule at 40 CFR 95 1.308. As you know, section 308(d)(3) of the rule requires states 

to consult with neighboring states on reasonable progress determinations for sources that affect 

Class I areas in those states. The purpose of this letter is to discuss our reasonable progress 

evaluations for North Carolina sources that may contribute to visibility impairment in South 

Carolina's Class I area, and to request that you share your evaluations for any sources in South 

Carolina that may contribute to visibility impairment in Class I areas in North Carolina. 

As you know, the North Carolina Division of Air Quality (NCDAQ) has been active in the 

Visibility Improvement - State and Tribal Association of the Southeast (VISTAS), the regional 

planning organization for the Southeastern United States. Through VISTAS we have been pleased 

to work directly with Renee Shealy, John Glass and others of your staff, and expect to continue to 

do so. 

North Carolina is home to five different Class I areas, as designated under Section 169A of 

the Clean Air Act. The State has a major interest in improving air quality and visibility at these 

Class I areas and all across North Carolina. That interest is best demonstrated by the adoption of 

the Clean Smokestacks Act (CSA) by the General Assembly of North Carolina during the 2002 

session. This landmark legislation establishes caps on the nitrogen oxide and sulfur dioxide 

emissions from the coal-fired power plants in the State. These caps can only be met with actual 

reductions in North Carolina; that is, no credits can be used to satisfy the cap and the utilities have 

agreed to transfer any allowances earned by these reductions to the State. I have attached the 

compliance plans provided by each of our two utilities showing which units are expected to install 

control equipment in order to meet these caps. 

The reasonable progress assessment is only one part of a larger effort to reduce emissions 

and improve air quality throughout the Southeast and Eastern United States. These efforts, like 

EPA's Clean Air Interstate Rule (CAIR) and North Carolina's CSA, generally require emission 

reductions of a whole class of significant sources, in particular coal fired electric generating units 

1641 Mail Service Center, Raleigh. NC 27699-1641 

2728 Capiial Bhrd., Raleigh, NC 27604 

Phone: 919-715-7670 1 Fax: 919-715-7476 1 Internet: ww.ncair.orq 

An Equal OpportunitylAffirmalive Action Employer - 50% RecycledllO% Post Consumer Paper 

Appendix J - 44
Myra Reece 

August 2,2007 

Page 2 of 4 

(EGUs). In contrast, the reasonable progress assessments were performed on a sub-source unit-byunit basis and for the specific purpose of evaluating impacts at Class I areas. 

It is important that we point out that North Carolina's concern over emissions of SO2 and 

oxides of nitrogen relates to much more than visibility impacts at specific Class I areas. North 

Carolina is also concerned about the serious health and welfare implications that these pollutants 

have in North Carolina. The public health concerns in particular demand a faster schedule of 

control than is required by the federal Regional Haze Rule. North Carolina is in fact pursuing these 

reductions in separate actions. 

For all of these reasons, the reasonable progress assessments below must be considered 

only within the limited regulatory framework of the Regional Haze Rule. 

NCDAQ Process on Reasonable Progress Assessment 

The following summarizes the general process NCDAQ used in making this Reasonable 

Progress Assessment: 

Step 1 : Determine ~ollutants of concern. 

As you know, VISTAS evaluated the species contribution on the 20 percent worst visibility 

days and concluded that sulfate accounted for greater than 70 percent of the visibility impairing 

pollution. The VISTAS States concluded that controlling sulfur dioxide (S02) emissions was the 

appropriate step in addressing the reasonable progress assessment for 2018. 

Step 2: Determine which source sectors should be evaluated for reasonable progress. 

Since SO2 point source emissions in 2018 represent greater than 95 percent of the total 

SO2 emissions inventory, the VISTAS States concluded that the focus should be on electric 

generating unit (EGU) and non-EGU point SO2 emissions. 

Step 3: Determine if the Clean Air Interstate Rule (CAIR) is sufficient for reasonable progress. 

The NCDAQ evaluated the amount of SO2 reduction from the EGUs due to both CSA and 

CAIR. The EGUs in North Carolina are expected to reduce their SO2 emissions by greater than 80 

percent between 2002 and 2018. Much of that reduction is the result of CSA requirements which 

are directly enforceable and which must be satisfied by actual emission reductions. In contrast, the 

SO2 emission reductions beyond CSA that are predicted by the Integrated Planning Model (IPM) 

to meet the CAIR requirements are not as certain due to the current rule's reliance on unchecked 

trading and the use of banked Title IV allowances. The NCDAQ intends to re-evaluate the IPM 

predictions of SO2 reductions for CAIR at the time of our next periodic report in 2012 to ensure 

that the reductions currently predicted by IPM for CAE do in fact take place where they are 

expected and needed. Based on the controls required by CSA, and predicted by PM under CAIR, 

we have concluded that at this time these existing regulatory programs constitute reasonable 

measures for North Carolina EGUs during this first assessment period (between baseline and 

2018). 

Appendix J - 45
Myra Reece 

August 2,2007 

Page 3 of 4 

Step 4: Determine which emission units would be evaluated based on impact. 

The NCDAQ calculated the fractional contribution from all emission units within the SO2 

Area of Influence for a given Class I area and identified those emission units with a contribution of 

one percent or more to the visibility impairment at that Class I area. 

Step 5: Evaluate the four factors. 

Each emission unit identified in Step 4 above was evaluated using the statutory and 

regulatory factors of 1) cost of compliance, 2) time necessary for compliance, 3) the energy and 

non-air quality environmental impacts of compliance, and 4) the remaining useful life of the 

emissions unit. For the limited purpose of evaluating the cost for the reasonable progress 

assessment in this first regional haze SIP, NCDAQ believes it is not equitable to require non-EGUs 

to bear a greater economic burden than EGUs for a given control strategy. 

Sources in North Carolina Affecting South Carolina's Class I Area 

Our analysis in step 4 of the reasonable progress assessment indicated there are no North 

Carolina units that contribute one percent or greater to visibility impairment at South Carolina's 

Class I area. The North Carolina facility with the greatest contribution to visibility impairment is 

Progress Energy's Weatherspn unit (Point ID G-26) in Robeson County, North Carolina, 

emissions from which contribute 0.2% of the visibility impairment on the 20% worst days at Cape 

Romain Wilderness Area. 

Under CSA, the Progress Energy system's SO2 emissions will be reduced from 195,765 

tons per year in 2002 to no more than 50,000 tons per year in 2013. The compliance plan for 

Progress Energy shows their projected emissions for 2013 to be 43,378 tons per year of S02. This 

level represents a 78 percent reduction in SO2 emissions from 2002. The 2013 compliance level is 

a system wide cap on emissions under the legislation. Although Progress Energy does not have 

plans to install scrubbers or other SO2 controls at the Weatherspoon facility, we do believe that 

their overall compliance plan under CSA represents reasonable progress for this first planning 

period of the Regional Haze State Implementation Plans (SIPS). It should be noted that Progress 

Energy, Duke Energy and other facilities in North Carolina that have units which contribute at 

least one percent to visibility impairment at any Class I area in the State, or in neighboring States, 

will be receiving a letter indicating that while no additional controls were identified during this 

reasonable progress assessment, that they should be addressing possible SO2 reduction strategies 

for the next round of regional haze SIP development. 

South Carolina Sources Affecting North Carolina's Class I Areas 

Your staff and mine have begun discussions informally about the Santee Cooper units 

(Point ID 003 and 004) in Berkeley County, South Carolina, and the Duke Energy Lee units (point 

ID 00 1,002, and 003) in Anderson County South Carolina. Our analysis (based upon VISTAS 

technical products) indicates that the Santee Cooper units have a greater than one percent 

contribution to visibility impairment at the Swanquarter Class I area in North Carolina and that the 

Appendix J - 46
Myra Reece 

August 2,2007 

Page 4 of 4 

Duke Energy Lee units have a greater than one percent contribution for Joyce-Kilmer Slickrock 

and Shining Rock Class I areas. We would like to request that you share with us your reasonable 

progress evaluation for these units when it is completed. 

I am attaching our schedule for the completion of the adoption of the regional haze SIP for 

the North Carolina Class I areas. There are two opportunities for you to provide information on 

the reasonable progress assessments of the units mentioned above: 1) prior to October 5,2007 so 

that the information can be part of the SIP document that is made available to the public on 

October 12,2007 in advance of the public hearings to be held during the week of November 12, 

2007, or 2) prior to the end of the public comment period which is scheduled to close sometime 

during the week of November 26,2007. 

Should your staff have any questions on this letter or on North Carolina's regional haze 

state implementation plan development, please contact Sheila Holman of my staff at (919) 715- 

0971. I look forward to continuing to work with you both directly and through VISTAS. 

Sincerely, 

-4 >dqdUL B. Keith Overc sh, P.E. - - 

Director 

Attachments 

Cc: John Hornback, SESARMIMetro4 Director 

Kay Prince, EPA Region 4 

Appendix J - 47
I 

NCDAQ Schedule for Completing and Submitting Regional Haze SIP 

Aug. 2,2007: Transmit draft SIP to FLMs and EPA. 

Week of Sept. 3: Hold meeting or conference calls with FLMs and EPA 

Oct. 5, 2007: Receive official written comments from FLM 

Oct. 12,2007: Make SIP document publicly available in advance of public 

hearing; include summary of FLMJEPA comments and our 

anticipated responses. 

Week of Nov. 12,2007: Hold two public hearings; one in Asheville, NC and one in 

New Bern, NC. 

Week of Nov. 26,2007: Close comment period for RH SIP. 

Dec. 17,2007: Transmit final SIP to EPA. 

Appendix J - 48
November 9, 2007 

B. Keith Overcash, P.E., Director 

North Carolina Div. of Air Quality 

1641 Mail Service Center 

Raleigh, NC 27699-1641 

 

Re: Regional Haze State Implementation Plans 

Dear Mr. Overcash: 

This letter is in response to your August 2, 2007, letter regarding the North Carolina Division 

of Air Quality’s (NCDAQ) Reasonable Progress Assessment under the Regional Haze State 

Implementation Plan. 

South Carolina is also preparing a State Implementation Plan (SIP) to address visibility and 

regional haze issues for our own Class I Federal area, the Cape Romain Wilderness area 

(Cape Romain). 

As your letter indicated, both the South Carolina Department of Health and Environmental 

Control (Department) and the NCDAQ, in developing their Regional Haze SIPs, must 

establish reasonable progress goals. In developing these goals, both the Department and 

NCDAQ should consider four “statutory factors,” including the cost of compliance, the time 

necessary for compliance, the energy and non air quality environmental impacts of 

compliance, and the remaining useful life of existing sources that contribute to visibility 

impairment. 

Your letter referenced several facilities in South Carolina that (based on VISTAS modeling) 

have a greater than one percent contribution to visibility impairment at one or more Class I 

Federal areas in North Carolina. Further, the NCDAQ requested that the Department 

consider sharing its reasonable progress evaluation for the following sources: Santee Cooper 

– Jefferies (Units 3 and 4) and Duke Energy – Lee (Units 1, 2, and 3). 

Similar to NC, the Department, in establishing its reasonable progress goals for the initial 

planning period, concluded that sulfate accounted for more than 70 percent of the visibility 

impairing pollution. As such, the Department has also determined that controlling SO2

emissions under the first planning period (2018) will have the most significant impact on 

reducing visibility impairment. 

Duke Energy: 

Duke Energy’s Lee plant operates EGUs subject to CAIR/CAMR. CAIR will permanently 

cap emissions of SO2 and NOx in the eastern United States. When fully implemented, CAIR 

will reduce SO2 emissions in these states by over 70 percent and NOx emissions by over 60 

percent from 2003 levels. CAMR will reduce utility emissions of mercury from 48 tons a 

year to 15 tons, a reduction of nearly 70 percent. As such, the Department finds that CAIR 

Appendix J - 49
Mr. Overcash 

November 9, 2007 

Page 2 

and CAMR-required SO2 controls for EGUs constitute reasonable measures for the first 

regional haze planning period. Moreover, it has been determined that the cost per ton of SO2

removed for all three Lee units is above the $2,000.00 per ton threshold that was selected by 

both NCDAQ and the Department as reasonable for EGU or non-EGU controls. It should 

also be noted that the Department has contacted Duke Energy to discuss future potential 

control requirements that may be necessary during the next round of regional haze SIP 

development. 

Santee Cooper:

Santee Cooper’s Jeffries plant also operates EGUs subject to CAIR/CAMR. However, for 

the purposes of preparing South Carolina’s Regional Haze SIP, Santee Cooper’s Jeffries 

facility (a BART-eligible source) was asked to perform and submit a modeling summary. 

Accordingly, the Department received a more in-depth analysis of this facility’s contribution 

to visibility impairment. Santee Cooper’s analysis of its Jeffries plant (using a four factor 

analysis) demonstrated that, for each of the boilers at the plant, the remaining useful life of 

these units is such that each source will likely be operating in 2018. The aforementioned 

BART analysis for Jeffries also demonstrated that current existing control technologies 

(ESPs and low-NOX burners) are adequate to maintain the uniform rate of progress for Cape 

Romain. Moreover, a 2004 Consent Decree with Santee Cooper Jefferies demonstrates that it 

is not feasible to further control its emissions. 

Therefore, the Department has determined that no additional control measures are necessary 

or feasible for the first regional haze planning stage for either Duke Energy or Santee Cooper. 

However, as required under Section 51.308(f), these elements will be reconsidered in the 

form of a progress report every five years, and, if necessary, a comprehensive SIP revision in 

2018. 

The Department is committed to improving air quality and appreciates this opportunity for 

consultation with you. Should you have any further questions concerning South Carolina’s 

regional haze SIP development, please contact Maeve S.R. Mason of my staff at (803) 898-

2230 or masonmr@dhec.sc.gov. 

Sincerely, 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and 

 Outreach, SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

 Pat Brewer, VISTAS Technical Advisor 

Appendix J - 50
MANE-VU VISTAS Consultation Meeting 

Atlanta, GA 

August 20, 2007 

Objective: Under the Regional Haze Rule, Section 51.308(d)(1)(i), where a State’s emissions 

are reasonably anticipated to cause or contribute to visibility impairment in a Class I area located 

in another State or States, the States are required to consult to develop coordinated emissions 

management strategies. The objective of this meeting was for the VISTAS and MANE-VU 

states to consult on emissions management strategies necessary and appropriate to assure 

reasonable progress visibility improvement in mandatory Class I Federal areas. 

Background: In June 2007, the MANE-VU States agreed to pursue the adoption and 

implementation of emission management strategies to assure reasonable progress toward 

preventing any future and remedying any existing impairment of visibility in mandatory Class I 

Federal areas and to leverage the multi-pollutant benefits that such measures may provide for the 

protection of public health and the environment. The MANE-VU States would have up to 10 

years to pursue adoption and implementation of reasonable and cost-effective nitrogen dioxide 

(NOx) and sulfur dioxide (SO2) control measures under the following emissions management 

strategies, as appropriate and necessary: 

• Timely implementation of BART requirements; and 

• A low sulfur fuel oil strategy to reduce sulfur content of distillate oil and residual oil by 

2012 (for inner zone States (New Jersey, New Your, Delaware, and Pennsylvania) and by 

2014 or 2018 for outer zone States (all other MANE-VU States) 

• A 90% or greater reduction in SO2 emissions from each of the electric generating unit 

(EGU) stacks identified by MANE-VU as reasonably anticipated to cause or contribute to 

impairment of visibility in the Class I areas in the MANE-VU region. If it is infeasible to 

achieve that level of reduction from a unit, alternative measures will be pursued in such 

State; and 

• Continued evaluation of other control measures including energy efficiency, alternative 

clean fuels, and other measures to reduce SO2 and NOx emissions from all coal-burning 

facilities by 2018 and new source performance standards for wood combustion. These 

measures and other measures identified will be evaluated during the consultation process 

to determine if they are reasonable and cost-effective. 

The MANE-VU states further agreed to request that States outside of the MANE-VU region that 

are identified as contributing to visibility impairment in the MANE-VU Class I areas pursue a 

course of action designed to assure reasonable progress toward preventing any future and 

remedying any existing impairment of visibility in Class I areas and to leverage the multipollutant benefits that such actions may provide for the protection of public health and the 

environment. This request for a course of action included pursuing the adoption and 

implementation of the following control strategies, as appropriate and necessary: 

• Timely implementation of BART requirements; and 

Appendix J - 51
 

• A 90% or greater reduction in SO2 emissions from each of the electric generating unit 

(EGU) stacks identified by MANE-VU as reasonably anticipated to cause or contribute 

to impairment of visibility in each mandatory Class I Federal area in the MANE-VU 

region. If it is infeasible to achieve that level of reduction from a unit, alternative 

measures will be pursued in such States; and 

• The application of reasonable controls on non-EGU sources resulting in a 28% reduction 

in non-EGU SO2 emissions, relative to on-the-books, on-the-way 2018 projections used 

in regional haze planning, by 2018, which is equivalent to the projected reductions 

MANE-VU will achieve through its low sulfur fuel oil strategy; and 

• Continued evaluation of other measures including measures to reduce SO2 and NOx 

emissions from all coal-burning facilities by 2018 and promulgation of new source 

performance standards for wood combustion. These measures and other measures 

identified will be evaluated during the consultation process to determine if they are 

reasonable. 

This long-term strategy to reduce and prevent regional haze will allow each State up to 10 years 

to pursue adoption and implementation of reasonable NOx and SO2 control measures. 

Meeting: 

David Littell, Maine Department of Environmental Protection and MANE-VU Chair, Anna 

Garcia, Ozone Transport Commission, and Dr. Carol Couch, Director of Georgia Environmental 

Protection Division provided welcome and opening remarks. 

Paul Wishinski, Vermont, provided overall of MANE-VU technical analyses and consultation 

objectives. 

• Sulfate is the major contributor to mass and haze on 20% worst visibility days at the 

MANE-VU Class areas. 

• REMSAD modeling indicates that VISTAS states may contribute greater than 1% to 

sulfate at MANE-VU Class I areas. 

• MANE-VU considered 4-factor analysis for SO2 controls for EGU, heating oil, 

industrial, commercial and institutional boilers, and cement and lime kilns and PM 

controls for residential wood combustion. 

• For EGU, MANE-VU is recommending 90% controls from 2002 emissions levels for 

167 EGU units and asking EPA to provide a third phase of CAIR (CAIR+). 

• MANE-VU states commit to a low sulfur fuel oil strategy that would reduce non-EGU 

emissions from MANE-VU states by 28%, therefore MANE-VU is asking VISTAS states 

to reduce non-EGU emissions by 28%. 

• MANE-VU states ask EPA to CAIR+ requirements. MANE-VU predicts that SO2 

emissions could be further reduced by 845,000 tons by 2018. 

• Next steps: SIPs are due 12/17/07 but enforceable emissions limits for proposed 

emissions strategies will be not implemented in time to include in SIPs. 

Pat Brewer summarized the VISTAS technical analyses that support state implementation plans 

(SIPs) including: 

• Sulfate is the major contributor to haze in the southeastern US and SO2 emissions 

controls would be the most effective measures to improve visibility 

Appendix J - 52
 

• VISTAS Base G2 inventory relies on IPM v2.1.9 EGU projections for CAIR updated 

with controls provided by the sources in summer 2006 and provided thee updates to 

EPA to be included in IPM version 3.0 (plus additional controls provided in January 

2007). VISTAS Base G2 inventories indicate that SO2 emissions from electric utilities 

in the VISTAS state will be reduced by 70% between 2002 and 2018. 

• VISTAS Base G2a emissions and air quality modeling results indicate visibility 

improvements on 20% worst days in 2018 greater than uniform rate of progress for all 

the VISTAS mountain Class I areas and many of the coastal Class I areas. For coastal 

sites, many of the 20% worst days are on cooler winter days when SO2 emission 

reductions are as large as in the summer months but sulfate formation is lower and so 

the benefit of SO2 emissions reductions is lower than on summer days. 

• VISTAS Base G2 model results also indicate visibility improvements on 20% best days. 

• VISTAS emissions sensitivity analyses indicate that further SO2 reductions from 

electric generating units and industrial sources would have the greatest visibility 

benefits, compared to other fine particle components. VISTAS states are major 

contributors to VISTAS Class I areas. MRPO, MANE-VU, and CENRAP are important 

source regions for Class I areas bordering these regions. 

• VISTAS SO2 Areas of Influence demonstrate the geographic areas most likely to 

contribute emissions to Class I areas on 20% worst visibility days. Electric utilities and 

industrial fuel combustion sources are the largest contributors to SO2 emissions in 2018 

in the Areas of Influence for all VISTAS Class I areas. 

• VISTAS states ranked SO2 sources in Areas of Influence by residence time and 

emissions divided by distance and considered 4 statutory factors for all sources with 

contributions greater than 1% (or 0.5%). 

• Most of the EGU in VISTAS states listed by MANE-VU will be controlled by 2018. 

MANE-VU requested additional EGU reductions of 187,000 tons per year beyond 

VISTAS Base G (MANE-VU OTW) inventory. The VISTAS Base G inventory already 

includes significant reductions for the top EGU list. VISTAS Base G2 SO2 emissions 

from EGU in the 7 states identified by MANE-VU will be 160,000 tons less than OTW. 

• MANE-VU states ask that VISTAS states consider a 28 % reduction in non-EGU 

emissions to match reductions that MANE-VU states expect are feasible from 

implementation of low sulfur fuel oil strategy for MANE-VU states. A low sulfur fuel 

oil strategy makes sense for the MANE-VU states because residential, commercial, 

industrial, and utility oil use accounts for 15-37% of the 2018 SO2 emissions in the 

Areas of Influence for the MANE-VU Class I areas. A low sulfur fuel oil strategy does 

not make sense for the VISTAS states because these source categories comprise 7-13% 

of the SO2 emissions in the VISTAS Areas of Influence. VISTAS states are evaluating 

reasonable control measures for non-EGU sources identified as contributors to VISTAS 

Class I areas. These results will be applicable to MANE-VU’s request for additional 

controls of VISTAS non-EGU emissions. 

• VISTAS discussions with sources suggest that MANE-VU estimates of costs of control 

may be lower than costs to individual sources. 

• VISTAS states will continue dialog with MANE-Vu states. 

Appendix J - 53
 

During the afternoon session States shared opinions on options for additional controls. Several 

options for future cooperation were discussed and in the session wrap up states committed to 

further discussion on potential control measures including: 

• additional EGU controls (EPA and CAIR+) 

• national fuel oil strategy 

• control requirements for coal-fired boilers for industrial, commercial and 

institutional sources 

• residential wood combustion change out or standards 

• reductions of SO2 emissions from marine vessels, diesel engines, rail 

• bio-diesel initiative 

• other non-EGU SO2 controls. 

Appendix J - 54
b 

United States Department of the Interior w-j 

OFFICE OF THE SECRETARY 

Wash~ngton, DC 20240 w 

TAKE PRIDE' 

,ocv 0 9 2007 INAM ERICA 

C. Earl Hunter, Commissioner 

South Carolina Department of Health 

and Environmental Control 

2600 Bull Street 

Columbia, South Carolina 29201 

BUREAU 01 rlii~ bu \i 

Dear Mr. Hunter: 

On August 17, 2007, the State of South Carolina submitted a draft implementation plan 

describing your proposal to improve air quality regional haze impacts at mandatory Class I areas 

across your region. We appreciate the opportunity to work closely with the State through the 

initial evaluation, development, and, now, subsequent review of this plan. Cooperative efforts 

such as these ensure that, together, we will continue to make progress toward the Clean Air Act's 

goal of natural visibility conditions at all of our most pristine National Parks and Wildernesses 

Areas for future generations. 

This letter acknowledges that the U.S. Fish and Wildlife Service has received and conducted a 

substantive review of your proposed Regional Haze Rule implementation plan in fulfillment of 

your requirements under the Federal regulations 40 CFR 5 1.308(i)(2). Please note, however, that 

only the Environmental Protection Agency (EPA) can make a final determination regarding the 

document's completeness and its ability to receive Federal approval. 

As outlined in a letter to each State dated August 1,2006, our review focused on eight basic 

content areas. The content areas reflect priorities for the Federal Land Management Agencies, 

and we have enclosed comments associated with these priorities. We look forward to your 

response, as per section 40 CFR 5 1.308(i)(3). For further information, please contact Tim Allen, 

Physical Scientist, Branch of Air Quality, at (303) 914-3802. 

Again, we appreciate the opportunity to work closely with the State of South Carolina and 

compliment you on your hard work and dedication to significant improvement in our Nation's air 

quality values and visibility. 

Sincerely, 

Assistant Secretary for Fish 

and Wildlife and Parks 

Enclosures (2) 

Appendix J - 55
U.S. Fish and Wildlife Sewice Comments Regarding 

South Carolina Draft Regional Haze Rule State Implementation Plan 

On August 17, 2007, the State of South Carolina submitted a draft Regional Haze 

Rule State implementation plan (SIP), pursuant to the requirements codified in federal 

rule at 40 CFR 5 1.308(i)(2), to the U.S. Department of the Interior, U.S. Fish and 

Wildlife Service (FWS), and National Park Service (NPS). The air program staff of the 

FWS has conducted a substantive review of the South Carolina draft plan, and provide 

the comments listed below. The comments which are highlighted in bold face are those 

that we believe warrant additional consultation prior to public release of the South 

Carolina Regional Haze Plan. We look forward to your response as per section 40 CFR 

5 1.308(i)(3). For further information, please contact Tim Allen (FWS Branch of Air 

Quality) at (303) 91 4-3802. 

HIGHLIGHTED COMMENTS: 

-p 

The SIP indicates that there are several Best Available Retrofit Technology 

(BART)' eligible sources which made significant modifications to the published 

"New IMPROVE" equation in analyzing their individual contributions to haze in 

the Cape Romain Wilderness Area. By means of targeted modifications to the 

IMPROVE equation, these sources were able to demonstrate a less than 0.5 deciview 

impact at Cape Romain. Therefore, these sources were exempt from further BART 

consideration. 

The SIP does not provide discussion or justifications for these changes to the new 

IMPROVE equation, nor are these modifications applied consistently throughout 

the regional haze analyses. It appears that these modifications were applied for the 

purpose of exempting sources from the full BART analysis and therefore creates 

inconsistency with respect to the entirety of the SIP. In addition, the SIP does not 

provide information that indicates that the US Environmental Protection Agency 

(EPA) has approved these specific IMPROVE equation modifications. 

The Fish & Wildlife Sewice strongly requests that the State present the results of 

the BART exemption analysis, for each source, using an unmodified version of the 

new IMPROVE equation. We also request that sources which do not demonstrate 

BART exemption, using the unmodified IMPROVE equation, conduct the requisite 

five factor analysis. 

I BART-eligible sources are those sources that have the potential to emit 250 tons 

or more of a visibility-impairing air pollutant, were put in place or under construction 

between August 7, 1962 and August 7, 1977, and whose operations fall within one or 

more of 26 specifically listed source categories. Under CAA section 169A(b)(2)(A), 

BART is required for any BART-eligible source which "emits any air pollutant that may 

reasonably be anticipated to cause or contribute to any impairment of visibility in any 

such area." 

Appendix J - 56
General Comments: 

The following appendices were not included with the August 17, 2007 draft 

submittal: 

Appendix D: Emissions Preparation and Results 

Appendix F: Model Performance Evaluation 

Appendix G: Modeling Results and Supplemental Analysis 

Appendix H: Reasonable Progress EvaluatiodLong Term Strategy 

Appendix J: Documentation of Consultation Among States and RPO's 

Appendix L: WINHAZE Images for the Class I Federal Areas 

Appendix M: Reductions Under CAIR 

Appendix N: Supplemental A01 Analysis 

Appendix 0: Supplemental New IMPROVE Algorithm Analysis. 

2. We are especially interested in the information contained in Appendix H: 

Reasonable Progress EvaluatiodLone, Term Strategy. We understand that much 

of the BART information is also contained in this appendix. We cannot provide 

full evaluation and comment on the SIP without having a complete submittal, 

which includes all appendices. Therefore, comments presented here do not 

consider the BART and Reasonable Progress portions of the SIP. 

The Regional Haze regulations, 40 CFR 5 1.308(i)(4), specify that "The plan (or 

plan revision) must provide procedures for continuing consultation between the 

State and the Federal Land Managers on the implementation of the visibility 

protection program required by this subpart, including development and review of 

implantation plan revisions and 5-year progress reports, and on the 

implementation of other programs having the potential to contribute to 

impairment of visibility in mandatory Class I Federal areas." Therefore, the FWS 

requests that additional information be provided by the State to address continued 

consultation with the FLMs on programs having potential to contribute to 

visibility impairment. For example, we recommend that South Carolina's Smoke 

Management Plan (SMP) be included as a potential contributing program to 

visibility impairment and therefore included as part of the periodic review. 

Attached is a suggested list of SMP review elements for consideration. 

4. Please add discussion of the South Carolina Department of Health and 

Environmental Control's (SC DHEC) evaluation of impacts to Class I areas 

beyond South Carolina to Section 10. 'Interstate Consultation on SC Contribution 

to Visibility Impairment in Class I Federal Areas in Neighboring States'. This 

discussion is referenced as part of an appendix; we would like to see this added to 

the SIP narrative. 

Appendix J - 57
5. The SIP and the South Carolina SMP should identify Cape Romain as a smoke 

sensitive area and prescribed burners should be required to apply the appropriate 

smoke management techniques to minimize smoke impacts. 

6. The SIP identifies Particulate Organic Matter (POM) and Elemental Carbon (EC) 

as being the second and third most important contributors to light extinction on 

the 20 percent worst and 20 percent best visibility days at Cape Romain. While 

POM is identified as being the second most important contributor to fine 

particulate matter (see page 2 l), the discussion concludes that controlling 

anthropogenic sources will have little effect. Please clarify this assertion by 

adding a discussion of the ratios of anthropogenic and non-anthropogenic POM 

contributions to total fine particulate matter. It should be noted that elevated 

levels of POM and EC are indicative of impact from wildfire and prescribed fire. 

Therefore, the SIP and the SMP should better address what is required of 

prescribed burners relative to minimizing impacts in the Class I area. 

7. Table 2.3-1 in the draft SIP illustrates natural background and baseline conditions 

for Cape Romain. Recently, errors in these estimates were discovered by CIRA. 

New estimates are available on both the IMPROVE and VIEWS websites. Also, 

please verify that all baseline and natural condition numbers match throughout the 

documents and State if these estimates were generated using the old or the new 

IMPROVE equation. 

8. Ammonia emissions are identified as important for the 20% worst, winter time 

visibility at Cape Romain. Figure 7.4-1 illustrates a single significant contributor 

to ammonia in South Carolina. Please clarify the source of this contribution and 

discuss South Carolina's consultations regarding ammonia emission controls. 

9. Industrial point sources are estimated to contribute 20% of the Sulfur Dioxide 

(SO2) emissions (see page 3 1, figures 4.2-1 and 7.4-1) and are an important 

contributor to visibility impacts at Cape Romain. However, SC DHEC 

determined that non-electric generating unit (EGU) controls are not cost effective. 

We would like to see more discussion regarding the cost-effectiveness of 

controlling these sources addressed in the "Reasonable Progress" sections of the 

SIP narrative. 

10. For clarity, please define the following terms in the text of the document: "RRF", 

"GCVTC", "GEOS-Chem", and "PSAT". 

1 1. Please identify whether glide slopes were produced using actual model output or 

the results of using a relative reduction factor. If these numbers were the result of 

a relative reduction, please provide a discussion of how they were generated. 

12. We recommend that a discussion be added which describes the reliability of the 

GEOS-Chem and PSAT data sets, similar to that addressing reliability of the 

CMAQ model. 

Appendix J - 58
13. Please include a discussion about the certainty of CAIR reductions in South 

Carolina. In other words, please include a discussion that expresses SC DHEC's 

confidence in the near-term level of reductions associated with CAIR. 

14. The SIP indicates that area source emissions are projected to increase (see pages 

56-57). Fire is indicated to be included in these area source projections. We 

would like the portion of these estimates, which is attributable to wildland or 

prescribed fire, to be specified. 

15. The SIP should detail how the emissions inventory for prescribed fire was 

generated, specifically whether this inventory considered planned burns or actual 

burns. For example, prescribed fire emissions inventories based on planned 

burned acres can significantly over estimate emissions should the actual burned 

acres be less than predicted. Also, please include a discussion of the . . . . anthropogenic contribution to inter&d-ions. -- 

16. Some of the graphics contained in the document are difficult to read. We 

recommend that the graphics be updated with a higher resolution, so that the 

reader can better decipher the information being presented. 

17. We would like to see a list of the sources located within the Area of Influence 

(AOI) of each Class I area. A summary list of these sources should be included in 

the SIP narrative, much like the identification and listing of BART eligible 

sources. Providing these sources by name will add clarity to the reasonable 

progress discussion, especially with respect to the cost effectiveness of controls 

for the non-EGU sources. 

18. Figure 7.5.5-2 entitled "Emission Contribution from Major Source Categories in 

the A01 for Cape Romain" lists source categories and their contribution to total 

SOz. Several fonts were utilized in the table, presumably to signify relative 

importance. Please apply fonts (bolding, size) consistently to better express the 

information presented in the table. 

19. Please provide more information regarding VISTAS modifications to EPA's 

AirControlNET database. 

20. In light of the uncertainties recognized by SC DHEC with respect to reductions 

predicted by the IPM in meeting the CAIR requirements, please add a discussion 

of other programs that will balance growth or relocation of emissions and the 

regional haze goals. For example, SC DHEC should include a discussion of the 

Prevention of Significant Deterioration /New Source Review program as a tool 

for considering emissions growth and its effect on the regional haze plan. 

Appendix J - 59
21. Please express reasonable progress goals in terms of deciviews, not deltadeciviews (see page 92, Table 8.0). 

22. Section 8, 'Reasonable Progress Goals', concludes that no cost effective controls 

are available for the sources evaluated in determining reasonable progress. The 

SIP narrative should include a list of the sources evaluated, as well as a summary 

of the costlbenefit analysis performed. 

Appendix J - 60
Attachment 1: Recommendations for Annual Smoke Management Program 

Evaluation 

The following data is recommended to be collected as part of an annual SMP evaluation 

Number of prescribed bums conducted and/or permits issued in South Carolina 

Number of acres treated (black acres) by prescribed burning 

Estimated emissions of PM 2.5 from prescribed burning 

Estimated prescribed burning emissions reduced as a result of the application of 

smoke management techniques - . . 

Number of acres treated by wildland fire use fires 

Estimated emissions of PM 2.5 from wildland fire use fires 

Number of acres burned (black acres) by wildfires 

Estimated emissions of PM 2.5 from wildfires 

Number of wildland acres treated by methods other than prescribed fire and 

wildland fire use fires 

Number of public complaints resulting from prescribed fire smoke 

Number of public complaints resulting from wildland fire use fire smoke 

Number of public complaints from resulting wildfire smoke 

Number of monitored exceedances of air quality standards related to prescribed 

fires 

Number of monitored exceedances of air quality standards related to wildland fire 

use fires 

Number of monitored exceedances of air quality standards related to wildfires 

Number of times monitored air quality data related to wildland fire was flagged 

by the State as an exceptional event, as well as by fire type (wildfire, prescribed 

fire and wildland fire use fire) 

Appendix J - 61
Smoke management research needs identified by South Carolina users of wildland 

fire 

Training conducted on the application of smoke management techniques (number 

of courses presented in South Carolina and number of persons trained) 

Public outreach conducted addressing the role of fire in wildland ecosystems and 

the tools and efforts wildland fire managers are using to minimize the amount 

andlor impact of air pollutant emissions from wildland fire 

Appendix J - 62
BOARD: 

Paul C. Aughny, III 

Chairman 

Edwin H. Coop~:r, I11 

Vice Chairmarl 

Steven G. Kisne~ 

Secretary 

WrEd PROMOTE PROTECT PROSPER 

C. Earl Hunter, Commissioner 

.bnratitcgdpmte~ thu be& qftbepdlic ad a6r man'- 

- 

BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

Coleman E Buckhouse, MD 

December 17,2007 

Mr. Tin1 Allen 

U.S. Fish & Wildlife Service 

73 -7 3 W. Jefferson, Suite 375 

Lakewood, CO 80235 

Re: Regional H:aze SIP Comments 

Dear Mr. Allen: 

South Carolina has prepared a draft SIP to address visibility and regional haze issues for 

the State's Class I Federal area, the Cape Romain Wilderness area. The Department 

suhnlittecl a notice to the South Carolina State Register in October 2007, soliciting 

co~v~nents onthe draft SIP. 

011 October 15,2007, the Department received comments from the U.S. Fish & Wildlife 

Sen ice on the State's per-hearing draft State Implementation Plan (SIP). The October 

co~n~nents were summarized in two sections. The portion entitled "Highlighted 

Commenls" is dedicated to the State's treatment of modifications made to the new 

IMPROVE equation in determining Best Available Retrofit Technology (BART) 

eligibility. Section I1 entitled "General Comments" addresses particular areaslspecific 

statemerlts in the SIP that Region 4 believes should be revised to more accurately 

describe the particular subject matter. , 3 

Thc Department appreciates the depth and specificity of the U.S. Fish & Wildlife Service 

in irs review of the State's SIP. The attached document serves to specifically address the 

co nunen ts received. 

Thc Department has considered these comments as well as additional comments 

subn~itted by other interested parties. In reviewing these comments, the Department has 

evaluated the significance of each in terms of addressing visibility impairment and has 

revtsed rhe SIP accordingly. The final SIP package is due to EPA by December 17, 

2007. The Department hopes that the changes made to the final SIP package serve to 

addrcss all the co~nments/concems that were submitted during the public comment 

pes~od. ?'he Department remains committed to improving air quality in the region and 

appreciates the opportunity to work with the U.S. Fish & Wildlife Service to produce the 

bes~ possible SIP. 

!SOUTH (:A ;OLINA -- D E P A R T M E N T O F H E A L T H AND E N V I R O N M E N T A L C O N T R O L 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 wwwscdhecgov 

Appendix J - 63
Mr. Tin1 Allen 

Page 2 

December 17,2007 

Should you have any further questions concerning South Carolina's regional haze SIP 

de~ elopalent, please feel free to contact me at (803) 898-2230 or masonmr@dhec.sc.szov. 

Sincerely,, 

Dil ision of Air.Planning, Development & Outreach 

Burcau of Air Quality 

Socit h Carolina Department of Health and Environmentiu ~onnoi 

Renee Shealy, Assistant Bureau Chief, SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

I'at Brewer, VISTAS Technical Advisor 

Appendix J - 64
- 3 - 

U.S. Fish and Wildlife Service Comments Regarding 

South Carolina Draft Regional Haze Rule State Implementation Plan 

Pursuant to the requirements codified in federal rule at 40 CFR 51.308(i)(3), the 

Department would like to respond the comments received by your organization as 

follows: 

HIGHLIGHTED COMMENTS:

The Department believes that changes/modifications to the new IMPROVE equation 

were necessary to adequately address visibility impairment at Cape Romain. The 

Department has added discussion and/or justification of these changes in the SIP 

narrative on page 84 and in Appendix O. 

General Comments:

Comments 1& 2 – Incomplete Appendices: Given the large amount of work related to 

the Regional Haze SIP submittal, the Department acknowledges that several appendices 

were not included in the State’s August 17, 2007, draft submittal. A large portion of 

these appendices were awaiting technical analysis. To address this issue, the State 

committed to providing these appendices to the U.S. Fish & Wildlife Service as soon as 

possible thereafter. With the assistance of Tim Allen, the state was able to gain access to 

an ftp site able to handle the size of many of the remaining documents, and as a result, 

upload them for review on September 28, 2007. Appendices F and O were prepared for 

the VISTAS states by several contractors and were made available for review from the 

Department’s website on November 21, 2007. 

Comment 3 - SMP: The Department appreciates the FWS requests that additional 

information be provided by the State to address continued consultation with the FLMs on 

programs having potential to contribute to visibility impairment, in particular the State’s 

Smoke Management Plan. While the Department initial choice to incorporate the plan as 

evidence of its commitment to addressing smoke and its potential contribution to 

visibility impairment at Cape Romain, the Department ultimately chose to revise 

Appendix M. The South Carolina Forestry Commission (SCFC) is the author of the SMP 

and as a result also has the responsibility of administering the SMP in the State. As 

pointed out by several other stakeholders, in order to avoid having to make revisions to 

the State’s Regional Haze SIP every time the SMP was revised, the Department 

determined that Appendix M would be revised to include just the Memorandum of 

Understanding between the Department and the SCFC. The Department feels that this 

compromise presents the best possible scenario for communicating the ongoing 

commitment to consultation with the SCFC. Recently this consultation has included 

several meetings with the SCFC to receive abbreviated Smoke Manager training as well 

as a presentation of their call centers and data tracking system. This experience was 

invaluable in terms of understanding ways in which both agencies can continue to work 

together to address the impacts of smoke throughout the State. In addition, it should be 

noted that the Department has begun the process of establishing additional opportunities 

to continue to work with the Forestry Commission (e.g., attending the BlueSkyRAINS 

Appendix J - 65
- 4 - 

training together and developing a workgroup consisting of members of both 

organizations) now and in the future. 

Comment 4 - Interstate Consultation: The Department believes it has addressed this 

concern. In completing its four factor analyses, the Department has relied upon 

consultation with neighboring states (primarily Georgia and North Carolina) for 

information related to how sources within South Carolina may contribute to visibility 

impairment in other Class I Federal areas located in other states. Chapter 10, along with 

portions of Appendix J, serves to address this issue and document the consultation 

process. Within the documentation, the Department has sought to define its analyses as 

well as examine several sources that may contribute to visibility impairment at Class I 

Federal areas in neighboring states. Santee Cooper: Jeffries and SCE&G: Canadys may 

contribute to visibility impairment at Wolf Island in Georgia. Duke Energy: Lee may 

contribute to visibility in both Joyce Kilmer-Slickrock and Shining Rock. Santee Cooper 

emissions may to contribute to visibility impairment at Swanquarter National Wildlife 

Area in North Carolina. It should be noted that Santee Cooper is some 425 miles from 

Swanquater, and therefore by definition, outside its Area of Influence. In addition, 

Santee Cooper: Jeffries and SCE&G: Canadys are EGU sources subject to CAIR, and 

South Carolina has determined that implementation of CAIR is equivalent to BART. As 

such, no formal additional controls were determined reasonable for either of these two 

South Carolina sources. In terms of Duke Energy: Lee, the Department has determined 

that further reductions are not necessary during this first planning cycle. However, as 

noted in correspondence contained in Appendix J, the Department has been in 

communication with Duke Energy to discuss future potential control requirements that 

may be necessary during the next round of regional haze SIP development. 

Comment 5 – Smoke Sensitive Area within the SMP: SC DHEC has determined through 

consultation with the SCFC that it would be inappropriate to categorically establish Cape 

Romain as a smoke sensitive area. Prescribed burn permits are issued based on site 

specific information obtained in an application. As a result, there are no steadfast smoke 

sensitive areas; rather, smoke sensitive areas are determined differently based on a 

myriad of characteristics particular to an area. 

Comment 6 – POM and EC: These comments have been addressed in the SIP narrative 

(page 23). These comments are also addressed in Appendix C of Appendix F. 

Comment 7 – Errors in Natural Background and Baseline Conditions: These errors have 

been addressed in the SIP narrative (page 21). 

Comment 8 – Ammonia Emissions: This comment has been addressed in the SIP 

narrative (page 23). 

Comment 9 – Non-EGU Controls: This comment is addressed in the State’s four factor 

analyses (Chapter 8). As part of the analyses, several non-EGUs were asked to submit 

four factor analyses to identify the reasonableness of additional controls. 

Appendix J - 66
- 5 - 

Comment 10 – Define Terms: This comment has been addressed in the SIP narrative in 

the List of Acronyms/Abbreviations as well as throughout the document (Chapters 3 and 

5). 

Comment 11 – Glide Slopes: This comment has been addressed in the SIP narrative 

(page 26). 

Comment 12 – Reliability: This comment has been addressed in Appendix F’s Appendix 

G. 

Comment 13 & 20 – Certainty of CAIR: This comment has been addressed in the SIP 

narrative (page 78). 

Comments 14 & 15 – Fire Contribution: This comment is addressed in Appendix F, 

Chapter 2 as well as Appendix D.2b. 

Comment 16, 18, and 21 - Graphics: This comment has been addressed throughout the 

SIP narrative. 

Comment 17 – Sources in AOI: Table 8.0-2 illustrates South Carolina’s approach to 

establishing reasonable progress goals by ranking the non-EGU sources that were found 

to contribute to visibility impairment in Cape Romain’s Area of Influence. 

Comment 19 - Modifications: This comment has been addressed in Appendix H of 

Appendix F (Appendix F -1075). 

Comment 22 – Reasonable Progress: This comment has been addressed in Chapter 8. 

Attachment 1: Recommendations for Annual Smoke Management Program 

Evaluation

Much of the data recommended to be collected in Attachment 1 is already being 

maintained by the SCFC (included in their annual reports). Where holes in this data 

exist, the Department is working with SCFC to develop a system to track this data for use 

in the next planning stage. 

Appendix J - 67
the SC RH SIP - -&Aa- -> 

From: <Ward. Nacosta@epamaiI.epa.gov> 

To: ~masonmr@dhec.sc.gov~, <GardneSR@dhec.sc.gov> 

CC: <Notarianni.Michele@epamail.epa.gov>, <Johnson.Brenda@epamail.epa.gov>, ... 

Date: 10/23/2007 6:50 PM 

Subject: Comments on the SC RH SIP 

Attachments: SC RH Draft SIP comments-Oct-2007-SEIVT 10232007.doc 

Good Day Maeve and Stacey, 

Thank you for the opportunity to review the draft RH SIP from SC. 

Attached are R4 comments on the SIP. We may have additional comments in 

the future. We encourage early drafts from our states. As previously 

stated, you are waiting on Appendix F and we may not receive an appendix 

N. If you make corrections to any of the Appendices or the SIP 

Narrative and have the opportunity to send them to us before the 

prehearing period, please feel free to do so. 

The comments attached are rather extensive. If you would like to have a 

call to go over the comments or if you have any questions on any of the 

comments made, we are available to do so. 

Thank you. 

(See attached file: SC RH Draft SIP comments-Oct-2007-SENT 10232007.doc) 

Have a wonderful day! 

Nacosta C. Ward, Environmental Scientist 

U. S. Environmental Protection Agency, Region 4 

Air, Pesticides & Toxics Management Division 

Air Planning BranchIRegulatory Development Section 

61 Forsyth Street, SW 

Atlanta, GA 30303-8960 

email: ward.nacosta@epa.gov 

telephone: (404) 562-9140 

facsimile: (404) 562-901 9 

Appendix J - 68
Comments on the South Carolina Pre-draft Regional Haze SIP 

General Comments 

The following comments represent EPA Region 4's review of the draft South Carolina 

Pre-draft Regional Haze State Implementation Plan (SIP). We appreciate the opportunity 

to review this draft SIP. Below are our comments on the materials that were submitted 

for review. Please note that because some sections and appendices were not submitted or 

developed, we will likely have additional comments in the future. 

1. Sea Salt Term in New IMPROVE Equation 

EPA Region 4 and the IMPROVE Steering Committee have recommended that 

chloride concentrations from IMPROVE monitors be used in applying the new 

IMPROVE algorithmlequation. EPA Region 4 has consistently recommended the use 

of this approach in our correspondence on BART-related issues and documents. EPA 

recently approved the use of the new IMPROVE equation pursuant to the state's 

request based on the recommendations of the IMPROVE Steering committee and a 

VISTAS methodology using chloride concentrations for sea salt. Comments dated 

March 5,2007 (See Attachment 1) on alternative methods to estimate sea salt for the 

new equations have been provided to the state in a March 23,2007 email to John 

Glass from Rick Gillam. Several South Carolina BART-eligible facilities have 

developed modeling reports and protocols to incorporate alternative approaches to 

achieve modeling visibility impacts below the state's 0.5 deciview (dv) threshold. 

The comments in Attachment 1 have not been fully addressed by the state andfor the 

sources using an alternative to chloride data for estimating sea salt. They should be 

addressed in the state's rationale for relying on an alternative sea salt methodology to 

exempt sources from assessing BART controls. 

It is unclear why South Carolina chooses to use chloride data with the application of 

the new IMPROVE equation for developing its reasonable progress goal for the Cape 

Romain Class I area yet allow alternatives to be used for BART modeling. Please 

provide an explanation for why chloride is acceptable for reasonable progress but not 

for BART modeling at these Class I areas in the state's regional haze SIP. 

It is unclear why a long-term estimate of elemental sodium (Na) for a 1994-2004 

period should be used to estimate sea salt in the new IMPROVE equation. None of 

the BART-eligible facilities' reports (1) discuss how these years were chosen, (2) 

explained why the years chosen were appropriate and representative of the 2001 -2003 

period for the BART modeling, and (3) explained why a long term average is better 

than data from 200 1 -2003. 

A proposed hierarchy of approaches to develop sea salt concentration from different 

sources of data is provided on page Appendix H.6-428 and was apparently used by 

some SC BART-eligible facilities. 

a) This hierarchy does not have any generic EPA approval for use in 

implementing the new IMPROVE equation for the BART assessment or any 

other application. 

Appendix J - 69
b) The hierarchy recommends use of data in the following order of preference 

when estimating sea salt from IMPROVE monitoring data: sodium ion (Na-); 

then chloride (Cl-); then elemental chlorine; and finally elemental sodium 

(Na). The following table provides the visibility impacts from the sources 

relying on an alternative sea salt estimation methods based on the proposed 

hierarchy. 

New IMPROVE Sea Salt Estimation Methods and BART Visibility Impacts 

I 1 I Not analyzed (NA) I NA I NA I NA I MI I 

Hierarchy 

NaC1 

Na 1 911 994-1 112001 I 1.1 1 0.437 1 0.477? 1 0.435 1 0.252 

* For International Paper (IP) Georgetown, it is not clear which method (i.e., Naor IVa) was used. ~he-cl- results should be provided. 

Period of data 

912002- 1212004 

i. It would appear that a hierarchy would result in impacts that were 

more conservative as one used the lowest method in the tiered 

approach. That is not the case with the proposed methodologies. It 

appears that more work is needed on this tiered methodology. . . 

11. There are several areas of uncertainty about the data used in the some 

of the documents in Appendix H.6. We recommend that the final SIP - - 

clarifies the areas above indicated with question marks. 

Sea salt concentration 

(ug/m3) 

0.77 

. . . 

111. Elemental sodium sea salt estimates should not be used as the basis for 

exempting a facility from BART if data from any of the higher tiers 

are available. Elemental sodium is the very last resort according to the 

proposed tiered approach. 

iv. Depending on the responses to the comments in Attachment 1, it may 

be that data and modeling impacts may change for the above facilities 

and the sources may have to rely on the chloride estimates for 

Visibility Impacts (uglm3) by BART-eligible facility 

DAK Coo~er I IP I Santee I Santee 

determining natural background. This would result in only the Santee 

Jefferies facility being exempt from BART. 

River 

0.471 

v. If the comments in ~kachment 1are not addressed, we recommend 

that the state of South Carolina rely on the chloride modeling impact 

results. 

vi. It is unclear if an entire year's data or data from the third quarter of 

years were used in the estimation of seas salt using sodium ion and 

elemental sodium data. Please clarify. 

vii. Given that a host of conclusions and results could arise from the 

choice of sea salt used, the state needs to clearly discuss their position 

and rationale on what number should be used for estimating sea salt 

for BART and other regional haze applications relying on natural 

Georgetown* 

Not presented 

background and the use of sea salt. 

Winyah 

0.476 

Jefferies 

0.273 

Appendix J - 70
. . . viii. We recommend that this table be included in the SIP with your 

discussions on the BART modeling. 

2. Many appendices contain hundreds to over a thousand pages of data and information. 

A table of contents with page numbers for each item is strongly recommended in each 

appendix. Otherwise, it is extremely difficult to review these documents. 

We recommend that the documentation for the BART SIP requirements include a list 

of all emission units at each facility, dates of operation, visibility impairing pollutants 

and potential emissions. The list or table should illustrate why each emission unit 

was or was not considered BART-eligible. If the unit was considered BART-eligible 

based on dates of operation and later determined not subject to BART, that reason 

should also be presented (i.e., if the source was determined to be exempt through the 

exemption modeling step). Additional suggestions for documentation that should be 

in the SIP are contained in a presentation given by Brenda Johnson at the EPA 

Region 4 State and Local Modelers Workshop held in March 2007. This presentation 

may be accessed on the following website: 

http://~~~.epa.gov/region4/air/modeling/workshop.htm 

4. Deciview Threshold and Modeling exemption: The exemption threshold value 

selected by the State in determining whether a BART-eligible source can reasonably 

be anticipated to cause or contribute to visibility impairment must be documented in 

the State Implementation Plan (SIP), as must the basis for the State's selection of this 

threshold. The threshold should be no higher than 0.5 delta deciview (dv) (e.g. >/= 

0.5 is subject to BART, < 0.5 is exempt per the BART guidelines). In establishing 

the threshold, States should consider the number of emission sources affecting the 

Class I Areas at issue, the magnitude of the sources' impacts, and the location of the 

Sources. (See 70 FR 391 61 -391 62, July 6, 2005.) For instance, all 14 of the state's 

BART-eligible facilities impacted the Cape Romain Class I area and eight facilities 

affected Wolf Island. That is a considerable overlap of impacts. The appropriateness 

of the threshold used by the State will be subject to public review and comment, and 

States could consult with the affected States or Regional Planning Organizations or 

Federal Land Managers in establishing this value. 

5. Referencing Websites 

a) Websites should not be used to direct the reader to information that is 

pertinent to the support of the official SIP submittal because the websites 

could move, the data could change or other reasons could occur to make the 

data and website inaccessible. Such references could be used in prehearing 

submittals, but not in the final SIP 

SIP Narrative 

1. Section 1.2 - What Are the Requirements Under the Clean Air Act for 

Addressing Regional Haze? 

Appendix J - 71
Under this section, we suggest the language in paragraph 1 on page 11 be revised as 

follows: 

The timing of the SIP submittal is tied to the EPA's promulgation of designations for 

the National Ambient Air Quality Standard (NAAQS) for fine particulate mattes 

(PM2 .- 5) pursuant to 40 CFR Part 8 1. States must submit a regional haze 

implementation plan to the EPA within three years after the date of designation. 

Because the EPA promulgated designations dates on December 17,2004, regional 

haze SIPS must be submitted by December 17,2007. 

2. Section 2.1 - Estimating Natural Conditions for South Carolina Class I Federal 

Areas 

a. The estimation of natural background is a critical component of technical 

analyses in the Regional Haze SIP. We highly recommend that this section or 

a new subsection address the technical manner in which natural background 

was developed for reasonable progress and for BART. It should also include 

the sea salt alternative approaches. Presently these discussions are presented 

in appendices. 

b. The title of this section should include "Class I Federal Area" since the state 

has only on Class I area. 

3. Section 2.3 should discuss or provide an appendix for the specific data used in 

applying the new IMPROVE equation for the reasonable progress goal determination 

in Table 2.3-1. 

4. The version of the Integrated Planning Model (IPM) used to develop future emissions 

for the electrical generating units (EGUs) of the point sources should be included in 

section 4.1.1.1. 

5. Conceptual Description 

a. The SIP Narrative should contain a summary discussion of the conceptual 

description of visibility and the conditions leading to and improving regional 

haze impairment in the Cape Romain Class I area. Appendix B should be 

referenced for more detailed discussions and information. 

b. Specific sections in Appendix B should be referenced for more details on the 

conceptual description. A general reference to Appendix B is inadequate as 

Appendix B has over 600 pages of data and information on all of the VISTAS 

areas of analysis. The state should pull out those portions that are relevant to 

this topic and Class I area. 

6. Appendices D and H references are indicated in many places in the SIP Narrative. 

However, there are nine sub-appendices of Appendix D and at least 6 sub-appendices 

of Appendix H included the SIP. Please indicate the specific Appendix D (e.g., 

Appendix D.3 or D.4b, or Appendix H) that is being referenced. 

7. Appendix F.2 is mentioned in Section 6.1 but is not included in the draft SIP 

Appendix J - 72
8. Model Performance Evaluation 

a. Section 6 six discusses the model performance evaluation using statistical 

analyses for the photochemical air quality modeling. We understand that the 

South Carolina (SC) modeling was a part of a technical project which 

included all of the Class I areas within the VISTAS States and for select NonVISTAS States Class I areas. We agree that the modeling performance results 

for the entire 12km modeling domain provide valuable information. 

However, Section 6 provides no information on the model's performance in 

an individual Class I area. We recommend that, at a minimum, this discussion 

address the model performance for the Cape Romain Class I area. This 

discussion could initially address the annual results for the state's Class I area 

andlor seasonal/monthly results could be referenced and discussed in an 

appendix. Other analyses for the entire domain could also be presented in an 

appendix. 

b. Model performance for the meteorological modeling should also be discussed. 

9. Section 7.1 - Overview of the Long Term Strategy Development Process 

a. This section should probably be renamed "Federal Measures and VISTAS 

States Local Controls "because it mostly discusses controls relied upon in 

developing the baseline future year emissions. 

b. We recommend separating all emissions used to develop the baseline future 

inventory (i.e., on-the books) from reductions not yet implemented or acted 

upon in a SIP revision. 

c. For clarity, we recommend that the SIP Narrative contain a section that 

specifically addresses the emissions reductions that the state of South Carolina 

is proposing and relying upon for its LTS at Cape Romain and to support 

Class I areas in other affected states. We recommend that BART reductions 

be clearly delineated from the other reasonable progress reductions. 

- - 

d. For clarity, we recommend that the SIP Narrative contain a section that 

specifically addresses the emissions reductions that states with sources that 

affect the cape Romain Class I area have agreed to implement as a result of 

the consultation process. 

e. Emissions reductions from a 2004 consent agreement were modeled for the 

Santee Cooper facility (See page 5 1 .) It is unclear how this consent agreement 

is enforced or made enforceable. 

10. Section 7.2.1, page 51: Please clarify why CAMR is included as a program 

providing expected visibility improvement, since mercury is not a visibility impairing 

pollutant? If this is a reference to the co-benefits for SOz control achieved by 

installing controls for mercury, this should be explained. 

11. Smoke Management Plan (SMP) Section 7.2.1 

a. Page 53: In the discussion related to the Smoke Management Plan, reference 

is made to Section 309 of the Regional Haze Rule. This discussion should be 

revised to clearly indicate that the requirements that apply for South Carolina 

are contained in Section 308, specifically 40 CFR Part 5 1.308(d)(3)(v). The 

Appendix J - 73
requirements in Section 309 only apply to States in the West with Class I 

areas addressed in the Grand Canyon Visibility Transport Commission 

(GCVTC) Report. 

b. Page 53 & Appendix H: A copy of South Carolina's Smoke Management 

Guideline for Vegetative Debris Burning Operations is included in Appendix 

H. EPA commends South Carolina for addressing air quality and visibility 

impacts from smoke resulting from forestry and agricultural burning. We 

would like to point out that if the SMP is incorporated into the SIP, a revision 

to the SIP will be needed whenever the SMP is revised or updated. Therefore, 

South Carolina may wish to discuss the benefits of the plan and reference that 

it exists, but may not want to actually incorporate it as an appendix in the SIP. 

Note that EPA is currently working to develop language that could be used to 

reference the SMP without actually incorporating it. This language will be 

shared once it is available. 

Identifying Sources for Reasonable Progress Control 

a. The discussions on the process to identify sources that are subject to a 

reasonable progress assessment for visibility improvement at the Cape 

Romain Class I area are contained in Sections 7.4, 7.5, 7.5.1, 7.5.2, 7.5.3, 

7.5.4, 7.5.5 and 7.7. The conclusion of these discussions would greatly 

benefit from a table that shows all of the sources that result from these 

analyses. 

b. The table mentioned above could also highlight those specific South Carolina 

and non-South Carolina sources that the state decided to target for emission 

reductions and for the four factor analysis for reasonable progress. 

c. A master list of incremental control measures and a final master spreadsheet 

of sources to consider for Reasonable Progress control is mentioned in section 

7.6 on page 74 but is not provided. The location of the table should be clearly 

referenced and included in the SIP. Is this the table in Appendix H.2.c? 

13. Section 7.7, Step 3 Determine if CAIR is sufficient for reasonable pronress 

a. A four factor analysis should also accompany the discussion in this section. 

EPA's federal register notice on CAIR is a possible option for information. 

14. Determine which emission units would be evaluated based on impact 

a. It appears that several rationales are provided to support the 0.5 percent 

contribution threshold used for screening sources for reasonable progress 

review. These include the BART rule 0.5 dv threshold, the NOx SIP Call 

state significance value, the CAIR state significance threshold and NAAQS 

significance impact levels. We recognize the state's need to support their 0.5 

percent choice. However, we fail to see a visibility impairment threshold for a 

single emission unit as being correlated to the EPA significance levels used in 

determining if an entire state's impact on an national ambient air quality 

standard (NAAQS) nonattainment area. Also, it remains unclear how the PSD 

significant impact levels for human health standards are relevant to a visibility 

threshold. 

Appendix J - 74
b. It would appear that the 0.5 percent reasonable progress visibility threshold 

should represent sources that were identified to occur in the intersection of the 

area of influence, back trajectory, residence time plots, and source categories 

analyses and found to have the greatest impact on the Cape Romain Class I 

area. The intersection of these analyses could result in those top tier sources 

with a 0.5 percent visibility impact threshold. 

15. Referencing Websites 

A MANE-VU website is referenced on page 77 of the narrative. We suggest that the 

pertinent sections of this document that are being used in the SIP be included in the 

SIP. Other such references should be revised. 

16. The topic for section 7.8 on page 77 does not address the controls for reasonable 

progress. Rather, it appears to introduce the BART rule requirement for the state. 

17. Table 7.8.2-1 and Section 7.8.2 

a. Table 7.8.2 represents a good start in summarizing the analysis of BARTeligible sources that need a BART determination. However, more information 

could be included and another table could be developed to support it. The 

following comments offer recommendations for revisions of this table. 

b. It is unclear what "VOC Exempt" means in Table 7.8.2 on page 79. 

Specifically, it is unclear if four of the sources only emit VOC emissions. If 

not, the section should discuss the potential emissions for the other pollutants 

emitted by the four sources. 

c. INVISTA -Spartanburg is listed in Table 7.8.2 as being VOC exempt but not 

included in the discussion on page 88. 

d. A table could be included that shows all of the emission units at each BARTeligible facility with the dates of operation and existence and all of the 

emission unit's pollutants' (i.e., VOC, NOx, S02, PM2.5) potential emissions. 

The bottom of this table would indicate the total of each BART-eligible unit' 

potential emissions for the facility. Finally the table could show if an 

emission unit was not BART eligible. 

e. The maximum visibility impacts for every BART source modeled is not 

included in Table 7.8.2-1. 

18. Section 7.8.3 Evaluation of Sources Subiect to BART in South Carolina 

a. Jefferies (P. 83): In the first paragraph, the peak visibility impact should be 

"0.774" instead of "0.646." 

b. IP Georgetown (p.86): In the third paragraph "0.456"for the three year high 

impact should be replaced with the highest value modeled, "0.477" from the 

98th percentile value. 

19. Section 7.8.3, page 81: The discussion refers to 9gth percentile delta deciview impact 

for the SCE&G Wateree being presented in Table 7.8.2-1. This information is not 

contained in Table 7.8.2-1. The table should be revised to provide the information. 

Appendix J - 75
20. Section 7.8.3.3, page 88: This section contains a brief discussion of the BART 

Model Plant Exemption. Table 7.8.3-1 provides information for three sources that 

used the model plant exemption. There is no indication in this table whether any of 

these three sources have particulate matter emissions that would also need to be 

considered for the model plant exemption. EPA addressed the issue of PM emissions 

in a Q&A that was developed in November 2006. A copy of the Q&A is included for 

reference in Attachment 3. The SIP should be revised to address PM emissions from 

the three sources used the model plant exemption. 

21. Table 7.8.3-1, page 88: The distance to the closest Class I area for Owens Coming is 

listed as 10 1.1 krn. This is very close to the 100 km threshold contained in the model 

plant exemption criteria discussed in the BART rule. Specific details showing how 

this distance was determined should be provided. For example, it is unclear if the 

distance from the actual stack location to the nearest boundary of the Shinning Rock 

Class I area or if there is more than one stack at the Owens Coming facility that could 

affect the closest distance estimate. Because of the uncertainty in the procedures that 

could be used to calculate the distance and the lack of documentation, EPA questions 

whether this facility is actually eligible for the model plant exemption. 

22. Section 8.0, page 93: This section contains the following statement: "A cost 

threshold of $2,000.00 per ton for controls was then applied." No justification is 

provided for selection of this cost threshold. The basis for selection of this threshold 

should be discussed in this section. 

23. Section 8.0, page 93: This section states that: "In addition, BART-eligible facilities 

were also removed from the list of sources to consider because BART sources have to 

undergo evaluations to determine the best control measures for each source." It is 

unclear from this statement whether sources (units) that are not BART-eligible at 

facilities which have BART-eligible sources are being removed from the list of 

sources that are being considered for the Reasonable Progress Four Factor Analysis. 

Sources that are not BART-eligible should not be removed from consideration under 

Reasonable Progress. 

24. BART Determinations 

a. We recommend an additional table be prepared that shows the visibility 

modeling impacts from the BART determinations per the base case and each 

applicable control that was assessed. This table could also include the cost 

analyses for controls. 

b. South Carolina Electric & Gas (SCE&G) Wateree Station (p. 81) 

i. Emission controls to be added to SCE&G7s Wateree station are 

discussed. The visibility improvement is presented. The emissions 

reductions expected from these controls should also be included in this 

section. . . 

11. The discussion of this source's BART determination references Table 

7.8.2-1 for the visibility impact for the modeling of a flue gas 

desulfurization (FGD) system. It is unclear how the exemption 

Appendix J - 76
modeling in this table also represents BART control modeling for SO2 

emissions. We thought that only PM2.5 and H2S04 emissions were 

modeled since SC has concluded that CAIR equals BART for the 

electrical generating units for NOx and SOz. 

25. Interstate Consultation - SC states on page 100 that "South Carolina has not asked 

any neighboring states to adopt any measures beyond what is proposed in each of 

their own SIPS." It would appear that whether or not a state could/should implement 

controls on sources identified in their states as impacting SC's Class I area would 

depend on a four factor analysis that shows controls before 201 8 is reasonable at this 

time. It would appear that this analysis would be developed on a source-by-source 

basis. 

26. The Santee Cooper "Jefferies" plant name is misspelled on page 83. 

Appendix B - Conceptual Description 

1. We recommend that the discussion in Appendix B that supports the state's decision to 

use the new IMPROVE equation be revised to incorporate the state's rationale for 

estimating sea salt for natural background using different methodologies for BART 

and-reasonable progress. This discussion is needed since the two applications are 

related and it is unclear-how consistency between them is being addressed in the 

regional haze SIP. 

2. On page 3-18, the following website is provided that appears to contain the data 

recommended revised assumptions to estimate natural-background visibility on the 

20% worst days. (http://vista.cira.colostate.eddTSSIToolsn;CTOEChecklist.aspx) 

However, when one tries to use this website a message is presented that says the 

resource cannot be found. Please see the above discussion on using websites in an 

official SIP submittal. 

3. The specific data (and source) used with the new IMPROVE equation to estimate 

each term for natural background conditions should be included in the SIP Narrative. 

Referencing a website for this data in the SIP is not recommended since websites 

often change, are removed or are unavailable for other reasons. 

Appendix H.6 - BART Modelinp Protocol and Analysis 

1. Appendix H.6 Summary 

a. This appendix contains 1742 pages of scanned modeling protocols and 

reports. A table of contents that highlights the individual protocols and 

reports with page numbers is recommended. Otherwise, the document is 

unmanageable and extremely difficult to review. 

b. Many of the protocols and reports contain modeling recommendations and 

procedures that EPA provided negative comments on in our review of the 

documents. We recommend that the state provide an appendix summary that 

states that some BART-eligible facility's protocols and reports contain 

Appendix J - 77
alternative modeling procedures that were not approved by the state for the 

BART assessment. For example, these alternative modeling approaches 

included line of sight, Method 7 ammonia-limiting, etc. It could also state that 

revised protocols were not always submitted to the state but the above 

mentioned non-approved modeling approaches were not used in the final 

modeling. 

2. The report starting on page Appendix H.6-457 indicates that the State's chosen 

visibility threshold of 0.5 deciview was exceeded by the Wellman, Voridian, Invista 

Sarl, and Bowater facilities. Apparently additional modeling for some or all of these 

facilities was developed to address the exceedances. It is unclear where revised 

modeling for the Voridian and Invista plants are located in the appendix. It would be 

extremely helpful if a summary at the beginning of Appendix H.6 could be developed 

to guide the reviewer to multiple modeling protocols and reports for facilities. 

3. Electronic modeling files that are referenced in the modeling reports provided in 

Appendix H.6 should be clearly labeled and submitted in electronic format in the 

regional haze SIP. 

4. Meteorological modeling documentation. - The location of the documentation for the 

development of the meteorological files (i.e., hardcopies of the CALMET input and 

output files) should be included in the SIP. At a minimum, the discussion should 

address all model options that were used to develop the CALMET modeling files. 

5. DAK Cooper River (DAK) Facility BART Modeling Report - see Attachment 2 

6. International Paper Georgetown (IP) (see Attachment 2) 

7. South Carolina Electric & Gas: Canadvs Station - 

Modeling results for the individual years used in the refined modeling should be 

provided. 

8. Santee Cooper Plants: Jefferies, Grainger and Winyah 

a. It is not clear why downwash was not modeled for the Jefferies power plant 

which is within 50 km (i.e., 45 km) of the Cape Romain Class I area. Such 

modeling is recommended by the VISTAS protocol and EPA. 

b. See previous comments on sea salt in the "General Comments" section above. 

9. BART Exemption Modeling Report for South Carolina Facilities Report (page 458') - 

See Attachment 2 for comments on this document. 

10. Smurfit-Stone Container: Florence Plant - The BART modeling report with visibility 

impact results does not appear to be in this appendix. 

Appendix K - Recommended Improvements for Mid-Course Review 

Appendix J - 78
This section discusses the short-comings in the analysis tools, models, and emission 

inventories used in the development of the 201 8 strategy. This is interesting information 

and probably should be considered and updated as available in future evaluations. 

However, the appendix discussion should also include information on the state's intent or 

effort to determine whether or not the 2007 SIP long term strategy with respect to control 

implementation, emissions reductions achieved and expected, and visibility 

improvement. If this is not occurring according to the strategy submitted in the SIP then 

recommendations on steps to implement corrections/adjustments should be discussed in 

the appendix. 

Appendix I - Data Access 

1. The procedures and plans for data archival and access for the VISTAS technical 

products and data was a very well organized and presented. 

2. The appendix should also include similar information on the archival and access of 

the input and output files for each BART exemption and determination modeling 

demonstration. 

Appendix J - 79
ATTACHMENT 1 

EPA Region 4 Review Comments on the Document Titled: 

Evaluation of Alternative Methods for Estimating Sea Salt 

Concentrations at Cape Romain, dated March 5, 2007 

EPA Region 4 appreciates the opportunity to review the Sea Salt Report developed by 

Ivar Tombach through the Visibility Improvement - State and Tribal Association of the 

Southeast (VISTAS). EPA Region 4 continues to endorse the recommendation made by 

the IMPROVE Committee for use of chloride ion to estimate sea salt concentration. 

However based on our preliminary review of this report, it appears that there could be a 

technical basis to support the use of other methods for determining the sea salt 

concentration for use in the new IMPROVE algorithm. EPA Region 4 recommends that 

the following additional comments be considered by the State in making this decision. A 

rationale for any approach that differs from our recommended procedure of using 

chloride ion concentration should be provided. 

1. The goal of this analysis is to find the best method for estimating natural background 

levels during modeled point source impacts at Class I areas for the BART visibility 

assessment. That said, it may be more important to select a sea salt level for periods of 

high point source impacts than to select a different sea salt algorithm. We recommend 

that the rationale for how the sea salt term is used in the new IMPROVE algorithm 

include a discussion of the connection/comparison/correlation of sea salt, meteorology 

and times of high point source impacts. 

2. It appears that uncertainty exists in the collection and analysis of sea salt data. It is 

unclear how the submitted report for determining the appropriate sea salt concentration 

would actually be implemented and used in a specific BART assessment. Information 

should be provided that discusses how data from specific years will be used in the BART 

modeling to determine visibility impacts. 

3. We recommend that the relationship between sea salt and sulfate concentrations be 

reviewed and discussed in the documentation. This discussion should be submitted for 

review by EPA and the FLMs. 

4. Blank problems on the nylon filters with respect to the analysis of chloride data was 

discussed in the report. No discussion of sodium ion ma+) blank data is included in the 

report. It appears that the standard operating procedure for INIPROVE monitors doesn't 

call for analysis of Na+, so there has never been a reason to look at Na+ blank values on 

those filters. VISTAS may have asked for analysis of blanks when they commissioned 

the cation analysis, but no information is provided in the report. The Na+ blank values 

for the nylon filters should be subtracted from the measured Na+ values. If it's not being 

subtracted but is relatively large, the sea salt estimates would be biased high. If the data 

are available, we recommend they be assessed and included in the documentation 

provided in the VISTAS report. 

Appendix J - 80
5. EPA Region 4's position on use of the new IMPROVE Equation and the procedure 

developed by VISTAS for implementing it with the CALPUFF model has been 

previously shared with South Carolina and the other Region 4 States via email in October 

2006. This position indicates that when the new IMPROVE algorithm is used, 

documentation explaining the rationale and implementation should be provided to EPA. 

For a case where a method other than the default procedure of using chloride ion 

concentration for estimating sea salt is used, we recommend that the rationale for using 

an alternate method should also be provided in the facility-specific BART modeling 

protocol or modeling report. 

6. Consultation with the Federal Land Managers is recommended in the BART 

assessment and ultimately in the development of a reasonable progress long term strategy 

for a class I area. We encourage the State to share the VISTAS report and our comments 

with the appropriate FLM for their review and comment on this sea salt issue. The FLMs 

have a great deal of expertise in the area of visibility impairment and EPA Region 4 

would value their input. 

7. It appears that the report has undergone a limited review as compared to the lengthy 

and varied discussions that were held with the Regional Haze Data Workgroup to 

develop recommendations on the use of the chloride ion for assessing sea salt in the new 

INIPROVE algorithm. These workgroup recommendations have been used by EPA 

Region 4 in our comments on the BART protocols for the Region 4 States and are also a 

part of the EPA modeling guidance for assessing the uniform rate of progress (i.e., 

glidepath) modeling for Regional Haze. 

8. We continue to remind the States that the BART assessment of a source is only one 

requirement for assessing a source for controls and compliance with the Regional Haze 

Rule. An exemption from controls through BART does not equate to an exemption 

through the Reasonable Progress assessment. 

We encourage the State to consider these comments in their decision on the BART 

modeling for their sources. We also look forward to reviewing the completed BART 

modeling reports for your sources. 

Appendix J - 81
ATTACHMENT 2 

The following are comments from the Environmental Protection Agency (EPA) Region 4 

on the CALPUFF-based modeling reports for the eight facilities listed below and as 

developed by TRC Environmental Corporation. The modeling report is included in 

Appendix H.6 of the draft South Carolina Regional Haze SIP. It was developed to 

address source-specific modeling to demonstrate compliance with the Best Available 

Retrofit Technology (BART) Rule. 

Facilities Reviewed: 

1. Wellman Ind: Palmetto 

2. Solutia, Inc. 

3. Voridian Eastman Chemical Co. 

4. Owens Corning: Anderson 

5. Honeywell: Clemson 

6. Bowater Inc. Pulp and Paper 

7. Shaw Industries: Anderson 

8. Stone Container Pulp and Paper Mill NCGISOG 

9. ISG Georgetown 

10. Invista Sarl: Spartanburg 

11. DAK Americas : Cooper River Plant 

12. International Paper - Georgetown 

Specific Facilitv comments 

1. The report on page Appendix H.6-457 indicates that exceedances of the state's 

chosen visibility threshold of 0.5 deciview was indicated for the Wellman, 

Voridian, Invista Sarl, and Bowater facilities using screening modeling and the 

24-hour maximum modeled visibility impact. The reports indicate that additional 

refined modeling was developed for some or all of these facilities. It unclear 

where the refined modeled in located in the appendix many of these facilities. 

2. Speciation data for the particulate emissions were not provided and modeled for 

the Solutia, Vioridan, Honeywell and Shaw facilities. Tables 2-3b, 2-4b, 2-7b, 

and 2-9b indicate that all PM emissions from the applicable BART-eligible 

emission units were equally divided between two size categories for primary 

organic condensable (POC) emissions. The report indicates that this is a 

conservative assumption because the PM emissions from non-combustion 

operations are predominantly fine and coarse filterable PM which have extinction 

efficiencies less than POC. The report should provide additional justification for 

modeling all PM emissions as POC. PM speciation information for many source 

types is available from a number of sources, including documentation available on 

the VISTAS website (http://www.vistas-sesarm.org/BART/calpuff.asp), EPA's 

AP-42, Compilation ofAir Pollutant Emission Factors 

Appendix J - 82
(http://www.epa.gov/ttn/chief/ap42/), and other reference data for pulp and paper 

operations (e.g., NCASI analyses). 

3. The VISTAS website contains a link to the Federal Land Managers (FLM) PM 

speciation worksheets which provide recommended PM speciation profiles for 

various source types, including cement manufacturing facilities. Information 

contained in these worksheets could be used for preparing an additional 

justification for assuming that all PM is POC is a conservative assumption. 

4. The version of the CALPOST model used in the BART modeling was not 

included in the report. 

5. It is unclear how emission rates for the modeling were developed and whether or 

not they represented the maximum 24-hour rates over the assessment years. 

6. The distance to the Class I areas modeled for each BART-eligible facility should 

be presented. 

7. The modeling report does not provide any indication that quality assurance and 

quality control (QAIQC) procedures in the VISTAS BART Modeling protocol 

were actually followed when performing the modeling. 

8. There should be a discussion of all emission sources at the facilities modeled in 

this report. This could be easily presented in a table that shows the applicability 

for a particular emission units and its pollutants for being BART eligible 

DAK Cooper River (DAK) Facility BART Modeling Report 

1. This facility relied on the use of sodium for estimating the sea salt concentration 

for use with the new IMPROVE equation. Several papers and documents are 

referenced in the appendix, to support this choice. (See pdf pages 424-437) 

These papers could be presented once by the state for all of the sources relying on 

these documents. Also, the comments in Attachment of this EPA comment by the 

facility. 

2. Copies of the CALMET input and output files were not included in the SIP for 

DAK. 

3. The report does not discuss the origin of the NO2 data, the year or years used to 

develop this data and why those years were used. EPA Region 4 has determined 

that it would be acceptable to use the total NOx concentration as a surrogate for 

NO2 (i.e., conservatively assume that all NO, is NOz). The total NO, 

concentration can easily be obtained when running CALPOST by turning on the 

switch to produce NO, concentration output - no changes to the CALPUFF 

modeling are needed. 

Appendix J - 83
International Paper Georgetown (IP) 

1. The BART modeling for the IP Georgetown pulp and paper mill is based on the 

new IMPROVE equation using sodium concentrations. EPA Region does not 

agree with the statement on page Appendix H.6-936 that implies that EPA Region 

4 rejects the use of sodium ion data because the current analytical method (i.e., Xray fluorescence) used since December 2001 does not accurately measure low 

concentration and the data monitoring of chloride data is uncertain. If we ejected 

this data, then we would disagree with the state's use of it in their reasonable 

progress analyses. 

2. See above comments on the sea salt documentation. 

3. Enclosures 1-4 to the April 30,2007 letter with final modeling results not 

submitted in appendix. See a similar comment for the DAK Cooper River 

facility. 

Appendix J - 84
ATTACHMENT 3 

Q: The BART Model Plant Exemption in 40 CFR Part 5 1, Appendix Y, 

Section 111 (70 FR 39162-39163, July 6,2005) does not address PM; it only 

considers emissions of SO2 and NOx. The BART Guidelines state that the Model 

Plant Exemption may be used if a BART-eligible source's emissions of SO2 or 

NOx or combined SO2 + NOx are less than 500 TPY, and the source location is 

greater than 50 km from the Class I area, and a 0.5 deciview contribution 

threshold is used by the State. The exemption may also be used if potential 

emissions of SO2 or NOx or combined SO2 + NOx are less than 1000 TPY, and 

the source is greater than 100 km from the Class I area, and a 0.5 deciview 

contribution threshold is used by the State. If a source has direct PM emissions, 

can the Model Plant exemption still be used? 

A: YES, the Model Plant exemption criteria can be applied to PM emissions 

as long as a justification for including PM is provided. The justification should 

address how the light extinction resulting from the PM emissions compares with 

the light extinction resulting fiom emissions of SO2 andlor NOx. The 

justification should include a brief analysis of the light extinction resulting from 

the individual PM species (e.g., elemental carbon, sulfates, etc.) in the source's 

direct PM emissions. Note that the model plant criteria apply to potential 

emissions--(this is not specified explicitly in the BART Guidelines). 

The Georgia Department of Natural Resources developed a justification which 

EPA Region 4 has found to be acceptable (see the attached Powerpoint 

presentation for details on Georgia's approach). The overall premise of Georgia's 

approach is to assume that the direct PM emissions are treated like SO2 emissions 

and thus are converted to sulfate (which typically has a larger impact on light 

extinction than NOx (nitrate) in the Southeastern U.S.). The approach presents 

two options: (1) assume that all direct PM emissions are converted to sulfate 

(most conservative option); or (2) consider the individual components of PM 

using a ratio of the light extinction efficiency of each species to the average 

sulfate extinction efficiency. Applying the Georgia procedure for either option 

results in the development of a "PM adjustment factor" (e.g., Model Plant 

adjusted PM emissions = 12 * PM emissions). The sum of SO2 + NOx + adjusted 

PM is then checked against the model plant criteria discussed above (e.g., is SO2 

+ NOx + 12*PM < 500 tonslyr?). 

It is important to note that Georgia's Model Plant PM justification methodology is 

an example only and is not for generic use without modification to account for 

site-specific conditions. It is not the only approach that may be acceptable. For 

the methodology to be used for other BART eligible sources, the specific 

assumptions and source-specific PM speciation profiles would need to be 

provided. The appropriate EPA Regional Office should be consulted when 

applying this procedure in other States. 

Appendix J - 85
USDA United States Forest National Forests in North Carolina 160 ZILLICOA ST STE A 

Department of Service Supervisor's Office ASHEVILLE NC 28801-1082 

Agriculture A 828-257-4200 

File Code: 2580 

Myra Reece Y 

SC Department of Health and Environmental Control 

Bureau of Air Quality 

2600 Bull St. 

Columbia, SC 29201-1797 

Dear Ms. Reece: 

Date: October 26,2007 

ECEUVE 

BUREAU OF AIR QUALITY 

On September 7,2007, we received a draft implementation plan from the State of South Carolina 

that describes your proposal to improve air quality regional haze impacts at mandatory Class I 

areas in your state. We appreciate the opportunity to work closely with the State through the 

initial evaluation, development, and now, subsequent review of this plan. Cooperative efforts 

such as these ensure that, together, we will continue to make progress toward the Clean Air Act's 

goal of natural visibility conditions at our Class I wilderness areas and parks. 

This letter acknowledges that the U.S. Department of Agriculture, U.S. Forest Service has 

received and conducted a substantive review of you~proposed Regional Haze Rule 

implementation plan. Please note, however, that only the U.S. Environmental Protection 

Agency (EPA) can make a final determination about the document's completeness, and therefore, 

only the EPA has the ability to approve the document. The Forest Service's participation in the 

State of South Carolina's administrative process does not waive any legal defenses or 

sovereignty rights it may have under the laws of the United States, including the Clean Air Act 

and its implementing regulations. 

Our review focused on eight basic content areas which reflect priorities for the Forest Service. 

We have attached comments to this letter. We look forward to your response required by 40 

CFR 51.308(i)(3). For further information, please contact Bill Jackson, Air Quality Specialist, at 

(828) 257-481 5 or Charles Sams, Regional Air Quality Program Manager, at (307) 578-8241. 

Again, we appreciate the opportunity to work closely with the State of South Carolina. The 

Forest Service compliments you on your hard work and dedication to significant improvement in 

our nation's air quality values and visibility. 

Sincerely, 

MARISUE H&'L&XRD 

Forest Supervisor 

cc: MaeLee Hafer, Charles E Sams, Ann E Mebane 

Caring for the Land and Serving People Pnnted on Recycled Paper 0 

Appendix J - 86
National Forests in South Carolina Comments 

SC Regional Haze State Implementation Plan (SIP) 

The SIP does not discuss how emissions from sources in South Carolina will affect 

visibility in Class I areas outside of South Carolina; specifically Joyce Kilmer-Slickrock, 

Linville Gorge, and Shining Rock and Cohutta Wildernesses. The information is 

contained in the Area of Influence (AOI) analyses and it would be appropriate to discuss 

how emission changes planned for South Carolina 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. 5 1.308 (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 which 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 Class I Federal areas." 

b. 5 1.308 (d) (3) (i) "Where the State has emissions that are reasonably anticipated 

to contribute to visibility impairment in any ... Class I area located in another 

State ..., the State must consult with the other State(s) in order to develop 

coordinated emission management strategies." 

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

State must ensure it has included all measures needed to achieve its 

apportionment of emission reduction obligations agreed upon through that 

process." 

Section 10, 'Interstate Consultation on SC Contribution to Visibility Impairment in Class 

I Federal Areas in Neighboring States', should include a list of South Carolina sources 

the A01 identified as having a potential to impact the Class I areas in Georgia and North 

Carolina. The list needs to include the pollution reductions that are anticipated at each 

source before 201 8. The SIP narrative should also include a summary of the costhenefit 

analysis performed for each facility. 

Currently, we believe the Duke Energy Lee facility (Anderson County) should be 

identified and discussed. The VISTAS emissions inventory indicates this facility emitted 

about 9,000 tons of sulfur dioxide in 2002. Our discussion with your staff has revealed 

this source will not be making any reductions under the Clean Air Interstate Rule, and the 

facility emissions of sulfur dioxide will remain the same (the VISTAS emissions 

inventory shows an increase of 6,763 tons per year) by 2018. We believe it would be 

appropriate to identify that this source is probably contributing to visibility impairment to 

Class I areas outside of South Carolina, and the source should anticipate making 

significant reductions either before or during the next Regional Haze Planning cycle. 

Appendix J - 87
2. The numbers used to produce Figure 7.2.3- 1 showing decreasing sulfur dioxide emissions 

between 2009 and 20 18 contradicts the numbers given in Tables 7.2.3- 1 and 7.2.3-2. The 

tables indicate emissions will increase for all the pollutants between 2009 and 2018, 

except nitrogen oxides. We have discussed this finding with your staff and have been 

advised the numbers in the tables are incorrect and the next version of the Regional Haze 

SIP will have the correct values. 

3. In Appendix J there is a reference to a letter submitted on 8/6/2007 by Keith B. Overcash 

(State of North Carolina) requesting consultation regarding South Carolina sources 

affecting North Carolina's Class I Areas. The letter was not present in the Appendix and 

should be included. Also, we are recommending the consultation meeting results be 

included in Section 10 and note any sources identified as having an impact to the Class I 

areas in North Carolina. 

4. As stated in the draft SIP, we agree with your finding that wildland fires emissions are 

not a significant contributor to visibility impairment at the Class I areas and further 

emission reduction techniques from prescribed fires are not needed before 20 18. Based 

upon this finding, it appears the current prescribed fire smoke management techniques 

implemented in South Carolina 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 South Carolina prescribed fire community are 

continuing to work together to refine the smoke management techniques to address 

ecological, human health and welfare needs. 

On October 9,2007, we discussed with your staff if the South Carolina Smoke 

Management Program (SMP) should be included as an Appendix or referenced in the 

Regional Haze SIP. Our recommendation is that any reference or citation of the SMP 

should maintain maximum flexibility to modify the South Carolina 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. 

5. The draft SIP does note a "reasonable progress report will evaluate the progress . . . for 

each mandatory Class I Federal area located outside South Carolina that may be affected 

by emissions from South Carolina sources." We recommend your agency explore the 

possibility of conducting a joint technical analysis with North Carolina, Georgia, 

Tennessee, Alabama, Kentucky, Virginia, West Virginia, Ohio, Pennsylvania, Maryland 

and the Federal Land Managers. Cooperation among these States would assist in 

developing the reasonable progress reports for all of the Class I areas in the southern 

Appalachians from West Virginia to northern Georgia. If all parties are agreeable to the 

idea then it should be noted in the final SIP. We believe it will be necessary for all the 

States listed to track how the actual emissions are changing by facility and source 

category between 2002 and mid-course review, and to what extent has visibility at the 

Class I areas in the southern Appalachians changed by the mid-course review. 

Appendix J - 88
BOARD: 

Paul C. Aught~y 111 

Chairman 

Edwin H.Coop:r, 111 

Vice Chairman 

Steven G. Kisner 

Secretary 

DHEC 

~!!l!!l~ PROMOTEPROTECT PROSPER 

C. Ed Hunter, Commisionu 

.bltreriqadpt~1'~atK bed& o,ftkpu& ad A tnhw 

BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

Decerm ber 1'7,2007 

Ms. Marisue Ilillard 

Forest Supervisor 

USDA Forest Service 

Post Office Box 2750 

Ashe\iIle, NC. 28802 

Dear Ms. Hi1 liard: 

South C'nrolina has prepared a draft SIP to address visibility and regional haze issues for the State's Class 

I Federal area, the Cape Romain Wilderness area. The Department submitted a notice to the South 

Carolina Stare Register in October 2007, soliciting comments on the draft SIP. 

On October 36, 2007, the Department received comments from the U.S. Department of Agriculture, U.S. 

1Torest Service on the Sfate's per-hearing draft SIP. The comments were summarized in several key 

points 

The Department appreciates the depth and specificity that the U.S. Forest Service reviewed the State's 

SIP. I'hc attached document serves to specifically address each of the comments received. 

The Department has considered these comments as well as additional comments submitted by EPA, FLM, 

and othet- interested parties. In reviewing these comments, the Department has evaluated the significance 

of each in terms of addressing visibility impairment and has revised the SIP accordingly. The final SIP 

package IS due to EPA by December 17,2007. We hope that the changes made to the final SIP package 

serve tc> address all the comments/concerns that were submitted during the public comment period. The 

Departnlcnt remains committed to improving air quality in the region and appreciates the opportunity to 

work w itll tht: U.S. Forest Service to produce the best possible SIP. 

Should ) ou have any further questions concerning South Carolina's regional haze SIP development, 

please feel free to contact me at (803) 898-2230 or masonmr(ir>,dhec.sc.tzov. 

Sincerel y , 

Robert J . Bro~n, .f!r., Director 

Division of Air Planning, Development & Outreach 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Renee Shealy, Assistant Bureau Chief, SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

SOUTH -- (:All OL[NA -- DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhecgov 

Appendix J - 89
2 

National Forests in South Carolina Comments 

SC Regional Haze State Implementation Plan (SIP) 

1. The SIP does not discuss how emissions from sources in South Carolina will affect 

visibility in Class I areas outside of South Carolina; specifically Joyce Kilmer-Slickrock, 

Linville Gorge, and Shining Rock and Cohutta Wildernesses. The information is 

contained in the Area of Influence (AOI) analyses and it would be appropriate to discuss 

how emission changes planned for South Carolina 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 which 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 Class I Federal areas." 

b. 51.308 (d) (3) (i) "Where the State has emissions that are reasonably anticipated 

to contribute to visibility impairment in any...Class I area located in another 

State..., the State must consult with the other State(s) in order to develop 

coordinated emission management strategies." 

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

State must ensure it has included all measures needed to achieve its 

apportionment of emission reduction obligations agreed upon through that 

process." 

Section 10, ‘InterState Consultation on SC Contribution to Visibility Impairment in Class 

I Federal Areas in Neighboring States’, should include a list of South Carolina sources 

the AOI identified as having a potential to impact the Class I areas in Georgia and North 

Carolina. The list needs to include the pollution reductions that are anticipated at each 

source before 2018. The SIP narrative should also include a summary of the cost/benefit 

analysis performed for each facility. 

The Department believes it has addressed this concern. In completing its four factor 

analyses, the Department has relied upon consultation with neighboring states (primarily 

Georgia and North Carolina) for information related to how sources within South 

Carolina will contribute to visibility impairment in other Class I Federal areas located in 

other states. Chapter 10, along with portions of Appendix J, serves to address this issue 

and document the consultation process. Within the documentation, the Department has 

sought to define its analysis as well as examine several sources found to have contributed 

to Class I Federal areas in neighboring states. Santee Cooper: Jeffries and SCE&G: 

Canadys were both found to contribute to visibility impairment at Wolf Island in Georgia. 

Duke Energy: Lee was found to contribute to visibility in both Joyce Kilmer-Slickrock 

Appendix J - 90
3 

and Shining Rock. Santee Cooper emissions were also found to contribute to visibility 

impairment at Swanquarter National Wildlife Area in North Carolina. It should be noted 

that Santee Cooper is some 425 miles from Swanquater, and therefore by definition, 

outside its Area of Influence. In addition, Santee Cooper: Jeffries and SCE&G: Canadys 

are EGU sources subject to CAIR, and South Carolina has determined that 

implementation of CAIR is equivalent to BART. As such, no formal additional controls 

were determined reasonable for either of these two South Carolina sources.

Currently, we believe the Duke Energy Lee facility (Anderson County) should be 

identified and discussed. The VISTAS emissions inventory indicates this facility emitted 

about 9,000 tons of sulfur dioxide in 2002. Our discussion with your staff has revealed 

this source will not be making any reductions under the Clean Air Interstate Rule, and the 

facility emissions of sulfur dioxide will remain the same (the VISTAS emissions 

inventory shows an increase of 6,763 tons per year) by 2018. We believe it would be 

appropriate to identify that this source is probably contributing to visibility impairment to 

Class I areas outside of South Carolina, and the source should anticipate making 

significant reductions either before or during the next Regional Haze Planning cycle. 

The Department has determined that further reductions are not necessary during this first 

planning cycle. However, as noted in correspondence contained in Appendix J, the 

Department has been in communication with Duke Energy to discuss future potential 

control requirements that may be necessary during the next round of regional haze SIP 

development. 

2. The numbers used to produce Figure 7.2.3-1 showing decreasing sulfur dioxide emissions 

between 2009 and 2018 contradicts the numbers given in Tables 7.2.3-1 and 7.2.3-2. The 

tables indicate emissions will increase for all the pollutants between 2009 and 2018, 

except nitrogen oxides. We have discussed this finding with your staff and have been 

advised the numbers in the tables are incorrect and the next version of the Regional Haze 

SIP will have the correct values. 

The Department appreciates this attention to detail and has revised the numbers in the 

table for its final SIP submittal. 

3. In Appendix J there is a reference to a letter submitted on 8/6/2007 by Keith B. Overcash 

(State of North Carolina) requesting consultation regarding South Carolina sources 

affecting North Carolina’s Class I Areas. The letter was not present in the Appendix and 

should be included. Also, we are recommending the consultation meeting results be 

included in Section 10 and note any sources identified as having an impact to the Class I 

areas in North Carolina. 

Appendix J has been updated to include documentation of all the consultation up to the 

point of final SIP submittal. 

4. As stated in the draft SIP, we agree with your finding that wildland fires emissions are 

not a significant contributor to visibility impairment at the Class I areas and further 

Appendix J - 91
4 

emission reduction techniques from prescribed fires are not needed before 2018. Based 

upon this finding, it appears the current prescribed fire smoke management techniques 

implemented in South Carolina 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 South Carolina prescribed fire community are 

continuing to work together to refine the smoke management techniques to address 

ecological, human health and welfare needs. 

On October 9, 2007, we discussed with your staff if the South Carolina Smoke 

Management Program (SMP) should be included as an Appendix or referenced in the 

Regional Haze SIP. Our recommendation is that any reference or citation of the SMP 

should maintain maximum flexibility to modify the South Carolina 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. 

The Department concurs with this finding, and as a result, has resolved to eliminate 

reference to the actual Smoke Management Plan (as this document was created and 

maintained by the South Carolina Forestry Commission). However, the Department 

remains committed to its ongoing relationship with the Forestry Commission and 

continues to work with them to improve the SMP. As a result, the Department has chosen 

to include the Memorandum of Understanding as a commitment to its ongoing 

relationship. In addition, it should be noted that the Department has begun the process 

of establishing additional opportunities to continue to work with the Forestry 

Commission now and in the future. 

5. The draft SIP does note a “reasonable progress report will evaluate the progress...for 

each mandatory Class I Federal area located outside South Carolina that may be affected 

by emissions from South Carolina sources.” We recommend your agency explore the 

possibility of conducting a joint technical analysis with North Carolina, Georgia, 

Tennessee, Alabama, Kentucky, Virginia, West Virginia, Ohio, Pennsylvania, Maryland 

and the Federal Land Managers. Cooperation among these States would assist in 

developing the reasonable progress reports for all of the Class I areas in the southern 

Appalachians from West Virginia to northern Georgia. If all parties are agreeable to the 

idea then it should be noted in the final SIP. We believe it will be necessary for all the 

States listed to track how the actual emissions are changing by facility and source 

category between 2002 and mid-course review, and to what extent has visibility at the 

Class I areas in the southern Appalachians changed by the mid-course review. 

The Department appreciates and accepts this opportunity to establish a joint technical 

committee to include the aforementioned states and FLMs. As such, this has been noted 

in the final SIP submittal (Chapter 11). 

Appendix J - 92
November 9,2007 

CERTIFIED MAIL 

Kay Prince, Chief, Air Planning Branch 

U.S. EPA, Region IV 

Atlanta Federal Center 

61 Forsyth Street Southwest 

Atlanta, Georgia 30303-8909 

Re: South Carolina Regional Haze Air Qual@y Implementation Plan 

Dear Ms. Prince: 

Section 169A of the Clean Air Act (CAA) provides for a national goal for visibility to include the 

prevention and remediation of manrnade air pollution, which contributes to the visible impairment of 

Class I areas throughout the country, including many well-known national parks and wilderness 

areas. As a result, in 1980, the EPA promulgated regulations to address visibility impairment that is 

"reasonably attributable" to one or a small group of sources located across a broad geographic area 

(referred to as regional haze). However, the EPA deferred action on regional haze regulations until 

monitoring, modeling, and scientific knowledge about the relationship between pollutants and 

visibility effects improved. In 1993, at the recommendation of the National Academy of Science 

(NAS) report, the EPA began conducting research into control technologies available for taking 

regulatory action to improve and protect visibility in Class I areas. On July 3 1, 1997, the EPA 

published proposed amendments to the 1980 regulations to set forth a program to address regional 

haze [62 FR 4 1 1381. On July 1, 1999, and July 6,2005, the EPA promulgated two rules known as 

the "Regional Haze Regulation (Regional Haze Rule)," and the "Regional Haze Regulations and 

Guidelines for Best Available Retrofit Technology (BART) Determinations," (also referred to as the 

BART Rule) respectively. 

The Regional Haze Rule [64 FR 357141 calls for States to establish goals and strategies for 

improving visibility in all of the country's 156 Class I national parks and wilderness areas. Cape 

Romain, South Carolina is one such Class I area. The EPA is requiring all states to revise their State 

Implementation Plans (SIPs) to reduce emissions of sulfur dioxide (SO*), oxides of nitrogen (NO,), 

and particulate matter--especially fine particulate matter (PM;? 5)--all of which contribute to regional 

haze and affect Class I areas. The CAA requires that any "major stationary source" that has the 

potential to emit 250 tons or more ofa visibility-impairing air pollutant that was put in place between 

August 7, 1962, and August 7, 1977, and whose operations fall within one or more of the 26 

specifically listed source categories would comprise a BART-eligible source and must install the 

BART for controlling emissions. States must address BART in their regional haze SIPs. 

Appendix J - 93
Page Two 

Regional Haze State Implementation Plan 

November 9,2007 

The EPA has established a schedule for states to submit their SIPS. South Carolina must submit its 

SIP under the Regional Haze Rule to EPA by December 17,2007. 

The South Carolina Department of Health and Environmental Control (SCDHEC) is diligently 

working to complete its SIP by the aforementioned date. A public hearing to discuss this plan is 

scheduled for Monday, November 26,2007. 

In a telephone discussion on Wednesday, November 7,2007, Ms. Nacosta Ward recommended that 

the Department provide an extension of the public comment period in order to encourage stakeholder 

involvement in the SIP amendment process. In accordance with Ms. Ward's request, the Department 

has, via electronic mailing and the Department's website, advised the public of an extension of the 

comment period through December 12,2007. Accordingly, the Department requests that EPA 

acknowledge the extension of the comment period and provide its comments on the amendment 

within that same timefhme. Ms. Ward also recommended that the Department resubmit the 

proposed SIP amendment in Ml. (The Department originally e-mailed the dmft SIP narrative and 

most of the supporting appendices to the EPA on August 2 1,2007.) Enclosed with this letter is an 

electronic copy of the proposed S@ amendment, including all associated appendices. 

The Department appreciates the assistance provided by you and your staff regarding the formulation 

of this plan. Should you or your staffhave any questions or comments concerning this SIP revision, 

please contact Ms. Maeve S.R. Mason of the Bureau of Air Quality at 803-898-2230. 

Sincerely, 

Robert J. Brown, Jr., Director 

Air Planning, Development and Outreach Division 

Bureau of Air Quality 

ec: Dick Schutt, Chief, Regulatory Development Section, EPA Region IV 

Nacosta Ward, Regulatory Development Section, EPA Region IV 

cc (lettter only): Stacey Gardner, Manager, Regulatory Development Section, BAQ 

CD enclosure (3 copies) - Regional Haze State Implementation Plan, South Carolina 

Appendix J - 94
Appendix J - 95
Appendix J - 96
Appendix J - 97
Appendix J - 98
Appendix J - 99
Appendix J - 100
Appendix J - 101
 

December 18, 2007 

Ms. Nacosta C. Ward, Environmental Scientist 

U.S. Environmental Protection Agency, Region 4 

Air, Pesticides & Toxics Management Division 

Air Planning Branch/Regulatory Development Section 

61 Forsyth Street, SW 

Atlanta, GA 30303-8960 

Re: Regional Haze SIP Comments 

Dear Ms. Ward: 

South Carolina has prepared a draft SIP to address visibility and regional haze issues for the 

State’s Class I Federal area, the Cape Romain Wilderness area. The Department submitted a 

notice to the South Carolina State Register in October 2007, soliciting comments on the draft 

SIP. 

On October 23, and December 12, 2007, the Department received comments from the US EPA – 

Region 4 staff on the State’s per-hearing draft State Implementation Plan (SIP). The October 

comments were summarized in two sections. The portion entitled “General Comments” is 

dedicated to the State’s treatment of a variety of substantive issues including the interpretation of 

sea salt in the new IMPROVE equation, and the exemption threshold value selected by the State 

in determining Best Available Retrofit Technology (BART) eligibility. Section II entitled “SIP 

Narrative” addresses particular areas/specific statements in the SIP that Region 4 believes should 

be revised to more accurately describe the particular subject matter. The December comments 

are organized into several sections entitled: (1) Sea Salt and New Improve Equation, (2) Best 

Available Retrofit Technology (BART), (3) SIP Narrative, (4) Appendices, and (5) General 

Comments. 

The Department appreciates the depth and specificity of EPA in its review of the State’s SIP. 

The attached documents serve to specifically address both sets of the comments received from 

EPA. Attachment A addresses the October comments, while Attachment B addresses the 

December comments received by the State. 

The Department has considered these comments as well as additional comments submitted by 

other interested parties. In reviewing these comments, the Department has evaluated the 

significance of each in terms of addressing visibility impairment and has revised the SIP 

accordingly. The final SIP package is due to EPA by December 17, 2007. The Department 

hopes that the changes made to the final SIP package serve to address all the comments/concerns 

that were submitted during the public comment period. The Department remains committed to 

Appendix J - 102
h4s. Ward 

December 18,2007 

Page 2 

impro~ ing air quality in the region and appreciates the oppmtunity to work with Region 4 to 

produce the best possible SIP. 

Should you have any fktkr questions concerning South Carolina's regional haze SIP 

development, please feel fiee to contact me at (803) 898-2230 or masonmr@,dhec.sc.rrov. 

Sincerely,, 

Robert J .' Brown, h., Director 

Ilivision of Air Planning, Development & Outreach 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Renee Shealy, Assistant Bureau Chief, SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

I'at Brewer, VISTAS Technical Advisor 

Appendix J - 103
Ms. Ward 

December 18, 2007 

Page 3 

Attachment A: EPA Comments received on October 23, 2007 

Section I: General Comments

Sea Salt Term in the New IMPROVE Equation 

The Department chose to address the bulk of the suggested changes put forth by Region 4 in 

Appendix O. Appendix O includes a letter addressed to EPA as well as several supporting 

documents that together address earlier concerns from the EPA dated March 23, 2007. 

Deciview Threshold and Modeling Exemption 

The exemption threshold selected by the State in determining whether a BART-eligible source 

can reasonably be anticipated to cause or contribute to visibility impairment is included in 

Appendix H, Section 7.4. The appropriateness of the threshold chosen by the State (0.5 delta 

deciview) while addressed in Appendix H, is also referenced in Chapter 7 of the SIP narrative. 

Referencing Websites 

The Department acknowledges the comments from Region 4 related to the potential future 

inaccessibility of data and websites used to support the State’s final SIP submittal. As such, 

references to websites within the SIP narrative and Appendices produced by the State have been 

removed. Supporting documentation for those remaining websites will be provided by the State 

in its final SIP submittal. 

Section II: SIP Narrative

Several of the suggested changes in this section were primarily related to verbiage and/or word 

choice, the Department chose to adopt nearly all of the suggested changes put forth by Region 4, 

including: Comments number 1, 2, 4, 5, 6, 9 – 16, 18, 19, 21- 23, 26. 

Comment number 7 addresses portions of Appendix F as not being included in the SIP submittal. 

Appendix F.2 refers to Appendix F, Chapter 2. These references have been clarified throughout 

the SIP. 

Comment number 8 is addressed in Appendix D of Appendix F. 

Comment number 17 has been addressed. Specifically, Appendix H.4 addresses 17.c, and 

updates to Tables 7.8.2 and 7.8.2-1 have been made. 

Comment number 24 has been addressed. Table 8.0-2 depicts the visibility impacts and cost 

analyses for potential controls for those sources included in a four factor analysis. Appendix H.6 

incorporates the BART modeling reports. 

SC DHEC appreciates comment number 25 and its reference to the importance of a case-by-case 

analysis. This is echoed in SC DHEC’s 4 factor analysis addressed in Chapter 8 of the SIP 

narrative. 

Appendix J - 104
Ms. Ward 

December 18, 2007 

Page 4 

Appendices H, K, and I have been updated according to the comments received. 

Attachment B: EPA Comments received on December 12, 2007. 

Several comments presented in this correspondence were echoed in the earlier document 

submitted by EPA Region 4. 

Sea Salt and the New IMPROVE Equation

The Department chose to address the bulk of the suggested changes put forth by Region 4 in 

Appendix O. A lead-in discussion has been incorporated in the SIP narrative on page 84 that 

addresses the State’s use of the sea salt term in the new IMPROVE equation. 

Best Available Retrofit Technology (BART)

TRC Environmental was contracted by VISTAS in April, 2006 to conduct BART exemption 

modeling for several sources in South Carolina. Specifically, ten sources were analyzed, 

including (among others) Solutia, Inc., Honeywell: Clemson, and Shaw Industries. 

Comment 1: The Department appreciates Region 4’s opinion related to the discrepancies in the 

use of sea salt in the new IMPROVE equation. As noted in the SIP narrative, SC DHEC has 

decided that compliance with CAIR satisfies sources’ requirements under the Regional Haze 

Rule for this first planning period. As indicated in the SC DHEC’s response to EPA’s comments 

(Appendix O.3), the Department remains confident that the end result for all the facilities 

required to submit a four factor analysis will be the same as if these facilities were required to 

submit a BART determination analysis for consideration of controls. 

Comment 2.a.: A subsequent evaluation by SC DHEC in the summer of 2006 clarified that the 

three aforementioned sources were non BART-eligible based on the boiler source. This has been 

addressed on page 81 of the final SIP narrative. 

Comment 2.b.: Correspondence between EPA and SC DHEC in June of 2006 (M. Notarianni to 

C. Bedenbaugh) clarified that sources determined to be VOC exempt, but that have been 

determined to emit other visibility impairing pollutants under the 250 tons/year threshold, can be 

found to be exempt from further BART determinations. This has been addressed on page 91 of 

the SIP narrative. 

Comments 2.c. and 3: Discrepancies between emission units located in Appendix H.4 and H.6 

exist because the information is presented differently. More specifically Appendix H.4 

(produced by SC DHEC) refers to stack ID numbers, while Appendix H.6 (produced by TRC) 

refers to unit ID numbers. 

Comment 2.d.: Voridian Eastman Chemical was found to be VOC exempt. However, prior to 

this determination, TRC, in its BART modeling report provided to VISTAS, evaluated this 

facility’s sources for BART exemption modeling. This has been addressed on page 92 of the SIP 

narrative. 

Appendix J - 105
Ms. Ward 

December 18, 2007 

Page 5 

Comment 4: Based on Department calculations, Albemarle should be included in the list of 

BART-eligible facilities, but was found to be VOC exempt. 

Comment 5: Addressed. 

Comment 6: The Department determined that Owens Corning and Milliken Chemical met the 

requirement of the BART model plant exemption. This determination took into account all of 

the visibility impairing pollutants (SO2, NOX, and PM). As noted in the VISTAS Procedures for 

Speciation of Emissions for VISTAS BART Modeling dated July 18, 2006, in many cased the 

speciation of particulate matter required for BART analysis will not be known. This is the case 

for Milliken Chemical. As such, consistent with the VISTAS BART exemption modeling, the 

Department has determined that it is overly conservative to assume that 100 percent of PM is 

elemental carbon. Therefore, the Department has chosen to defer to the default assumption; that 

the organics (OC) category with an extinction efficiency of 4.0 is the most reasonable extinction 

category in which to characterize unknown PM. With this in mind, the Department multiplied 

the potential PM emissions for each model plant source by a coefficient of 4.0 and then added it 

to the potential NOX and SO2 emissions to determine Milliken’s combined allowable emissions 

(tons/year). The table below illustrates this evaluation. 

Source Potential 

PM 

Emissions 

Extinction 

Efficiency 

Calculation 

Potential 

NOX + SO2

Emission 

Total Combined 

Allowable 

Emission 

Milliken 21 21*4 = 84 408 492 

 

Comment 7: Several Appendices found within the SIP narrative do not specify which section of 

these Appendices is being referenced. This request has been addressed throughout the narrative 

by noting chapters wherever possible (see “SIP Narrative” comment 2.a). However, certain 

references (e.g., Appendix H) refer to the actual text of Appendices themselves, and as a result 

remain unchanged. 

Comment 8: Documentation of the meteorological files (e.g., hard copies of the CALMET input 

and output files) were requested to accompany the final SIP. This seems to contradict a latter 

statement by Region 4 that explains that the Region will accept electronic versions of paper 

copies of documents that another state in Region 4 has already officially submitted with its final 

SIP (“SIP Narrative,” comment 4). The Department has made a note of this in the cover letter of 

the final SIP submittal. 

Deciview Threshold and Modeling Exemption 

The exemption threshold selected by the State in determining whether a BART-eligible source 

can reasonably be anticipated to cause or contribute to visibility impairment is included in 

Appendix H, Section 7.4. The appropriateness of the threshold chosen by the State (0.5 delta 

deciview) is also addressed in Chapter # of the SIP narrative. 

SIP Narrative

Appendix J - 106
Ms. Ward 

December 18, 2007 

Page 6 

1. Estimated Natural Conditions: Addressed in Appendix F, Chapter 4 (cited in Narrative). 

2. Model Performance Documentation: Chapter 3 of the Emissions and Air Quality 

Technical Support Document (Appendix F in SC SIP) includes a detailed model 

performance evaluation for the VISTAS region. In Appendix B of the Technical Support 

Document, additional graphics and statistics are discussed for each component of PM2.5 

for the VISTAS region. Appendix C of the Technical Support Document provides 

statistical tables for several model performance criteria, scatter plots, and bugle plots that 

demonstrate performance for each Class I area for the 20% Best and 20% Worst visibility 

days. Performance statistics for Cape Romain are very similar to those discussed for the 

region as a whole. 

In Appendix C, Section 2.3.11, time series line graphs in Figure C-57 compare modeled 

components of PM2.5 to IMPROVE measured vales for the annual 2002 modeling period. 

The model captured the temporal patterns for SO4; however, the model significantly 

under predicted SO4 on four summer days with high (>8 μg/m3

) measured SO4 peaks and 

significantly over predicted SO4 on several consecutive fall days with low (<4 μg/m3) 

SO4 values. NO3 model performance is poor; over predicting NO3 values in the cold 

months (1st and 4th quarters) and under predicting NO3 in the warm months (2nd and 3rd

quarters). The NO3 under prediction is not of concern because observed values are 

generally less than 0.5 and so NO3 does not contribute significantly to visibility 

impairment on these days. The NO3 over prediction in winter months is of greater 

concern because the relative reduction factors for NO3 may be affected by model 

performance. Over prediction of winter time ammonia values may be the reason for the 

over prediction. The model captures temporal trends for organic carbon and elemental 

carbon, including winter peaks, although some summer time peaks were over predicted. 

Soil was generally over predicted while coarse mass was generally under predicted. In 

composite, PM2.5 mass was generally under predicted. 

These same trends are presented in scatter plots and bugle plots for the 20% Best and 

20% Worst days in Figures C-53-C56. For the 20% Best days, scatter plots show general 

under prediction for all components except soil. Bugle plots for the 20% Best days show 

that EC and soil meet the goal, SO4, NO3, and coarse mass meet the criteria but not the 

goal, and OC is slightly greater than the criteria. For the 20% Worst days, scatter plots 

show some what better performance for SO4 and OC than on the 20% Best days, while 

bugle plots indicate that EC, soil, and coarse mass meet the goal, SO4 and OC meet the 

criteria but not the goal, and only NO3, with very low observed values, does not meet the 

criteria. Plots for sea salt are inconsistent among the figures and suggest that there were 

some problems with the plotting program that need to be resolved. 

These performance results suggest that model performance is acceptable for both the 20% 

Worst and the 20% Best days and that there is somewhat more confidence in model 

projections for the 20% Worst than the 20% Best days. 

3. Section 7.7, Step 4: Addressed on page 79 of the SIP narrative.

4. Title of Table 8.0-2: Addressed.

Appendix J - 107
Ms. Ward 

December 18, 2007 

Page 7 

5. Referencing Websites: Addressed within SC DHEC-produced documentation.

6. Interstate Consultation: SC DHEC appreciates this comment and its reference to the 

importance of a case-by-case analysis. This is echoed in SC DHEC’s 4 factor analysis 

addressed in Chapter 8 of the SIP narrative. 

7. Addressed on page 99 and 100 of the SIP narrative.

8. Addressed on page 53 of the SIP narrative and page 6 of Appendix H.

9. Addressed on page 78 of the SIP narrative.

Appendices

Appendix F: Appendix D has been addressed. 

Appendix H: All of the items in Appendix H have been addressed. 

The “miscellaneous” category referenced in Figure 1-1 refers to EPA Tier I categories. The 

miscellaneous category includes area sources not identified in previous categories. For example, 

agricultural emissions and fire emissions fall into this category. Agricultural emissions, both 

from fertilizer and livestock, are major sources of NH3. Fire emissions (wild fire, prescribed 

fire) may be a major contributor of primary carbon (PM2.5 and PM10). 

 

Appendix I: This appendix has been updated to include instruction for the archival and access of 

each BART exemption and determination modeling demonstration (see Appendix I.2). 

Appendix J: Addressed. 

Appendix L: The Department appreciates Region 4’s opinion when it comes to the necessity of 

including WIN HAZE images for each of the VISTAS Class 1 areas. These images were 

included at the request of another commenter. The Department also chose to include all of the 

images in order to present a clear view of projected visibility improvement in the entire VISTAS 

region. 

Appendix O: Comment 1 has been addressed. Comment 2 questions the Department’s decision 

not to request a four factor analysis from Santee Cooper Winyah. Based on the four factor 

discussion from the SIP narrative (Section 8.1) it is evident that Santee Cooper Winyah was not 

among those sources identified as having a Q/d greater than or equal to five and an RTmax 

greater than or equal to 10 percent. As indicated in the SC DHEC’s response to EPA comments 

(Appendix O.3) (see also Comment 1 above), the Department remains confident that the that the 

end result for all these facilities required to submit a four factor analysis will be the same as if 

these facilities were required to submit a BART determination analysis for consideration of 

controls. 

 

Appendix J - 108
BOARD: 

Paul C. Aughtry, 111 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisne~ 

Secretary 

BOARD: 

Henry C. Scorr 

M. David Mirchell, MD 

Glenn A. hdcCall 

C. Earl Hunter, Commissioner Coleman F. Buckhouse, MD 

fiornoring irizd pi-otrcti~g the hcnirh cf the /]lrl,lic rriid tlvr c,~zl,iro~i,n~lzt 

December 7,2007 

Mr. Tom Kerr 

Albemarle Corporation 

Post Office Box 1028 

Orangeburg, SC 29 1 16- 1028 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Kerr: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by Albemarle (1 860-0004). The purpose of the modeling demonstration is 

to show that the emissions from the BART-eligible source(s) at the facility do not cause or 

contribute 0.5 deciviews or greater visibility impairment in any Class I Federal area, thus 

exempting the sowce(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

Albemarle islare hereby exempt from further BART determinations. SCDHEC will include 

documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

niasonmr -.- 11 dlicc.sc.goi. 

Sincerely, 

Myra C. Reece, Chief ' 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacev Gardner, Manager, Regulation Development Section, SCDHEC 

Pat ~iewer, VISTAS Technical Advisor 

Permit File 1860-0004 

H AND ENVIROKMENTLXI C:ON7rKOl 

e: (803) 898-3432 www.scdhec.gov 

Appendix J - 109
BOARD: 

Paul C. Aughtry, I11 

Chairman 

Edwin H. Cooper, 111 

Vicr Chairman 

BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

Steven G. Kisner 

Secretary 

December 7,2007 

C. Earl Hunter, Colnlniss~oner 

I'romot~)zg and pmtecttng the heaith of the public and the ~i~z,rron7ne/zt 

Glenn A. McCaII 

Colern;~n F. Buckhouse, MD 

Mr. Dan Herlihy 

Stone Container Corporation 

Post Oflice Box 100544 

Florence, SC 29501 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Herlihy: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by Stone Container Corp. (1040-0003). The purpose of the modeling 

demonstration is to show that the emissions from the BART-eligible source(s) at the facility do 

not cause or contribute 0.5 deciviews or greater visibility impairment in any Class I Federal area, 

thus exempting the source(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

Stone Container islare hereby exempt from further BART determinations. SCDHEC will 

include documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

mabonmr --- trltiht.c.ssov. 

Sincerely, 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 1040-0003 

SOUTH (;IZROI,INX DEPXKTMFNT OF HEAI>TH AND ENYIRONMENTAL CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 110
BOARD: 

Paul C. Aughtry, I11 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisner 

Secretary 

December 7,2007 

PKOMO'I'E PROTECT PROSPER 

C. Earl Hunter, Commissioner 

P~onzot/ng nndprotect~n~ tilehorlth of thepublzr and thcz rnuironmerrt 

BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

Glenn A. McCall 

Coleman F. Buckhouse, MU 

Mr. Brent A. Pace 

BP Amoco Chemical Company 

1306 Amoco Drive 

Wando, SC 29492 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Pace: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by BP Amoco Chemical Company on behalf of its Cooper River Plant 

(0420-0029). The purpose of the modeling demonstration is to show that the emissions from the 

BART-eligible source(s) at the facility do not cause or contribute 0.5 deciviews or greater 

visibility impairment in any Class I Federal area, thus exempting the source(s) from further 

BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

the Cooper River Plant islare hereby exempt from further BART determinations. SCDHEC will 

include documentation to this effect in its final SIP submittal. 

Should you have any fbrther questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

In,i\onnlr i<dhcc.sc.go\. 

Sincerely, 

n 

I - 

Myra C. Reece, Chief 

~&eau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 0420-0029 

SOUTH C A R O L I N A D E P A R T M E N T OF HEALTH AND ENVIRONMENTAL CONTROL, 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 111
BOARD: 

Paul C. Aughtry, 111 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

Steven G. Kisner 

Secrerary C. Earl Hunter, Commissioner ( 

I'~ow7oting n~~dprotecti?z~~ tile I~cc~lth ofthr public and the enuironmri1t 

Glenn A. McCall 

Soleman F. Buckhouse. MD 

December 7,2007 

Ms. Jaquelyn Taylor 

Bowater Incorporate - Pulp and Paper 

Post Office Box 7 

Catawba, SC 29704 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Ms. Taylor: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by Bowater Incorporated (2440-0005). The purpose of the modeling 

demonstration is to show that the emissions from the BART-eligible source(s) at the facility do 

not cause or contribute 0.5 deciviews or greater visibility impairment in any Class I Federal area, 

thus exempting the source(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

Bowater Incorporated islare hereby exempt from fbrther BART determinations. SCDHEC will 

include documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

l&isonmr ir cil~g.\c.go\ . 

Sincerely, ..? 

Myra C. Reece, Chief / 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, ~ivision of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 2440-0005 

SOUTH CAROLINA DEPARTMENT OF HEA1,TH AND ENVIRONMENTAL 

-- ---- CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 112
BOARD: 

Paul C. Aughtry, Ill 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisner 

Secretary 

DHEC Ban 

PROhlOTE PRO'I'ECT PROSPER 

C. Earl Hunter, Commissioner 

Promoting nndpr.otecting the health of the pub/ir and the environment 

BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

December 7,2007 

Ms. Lily Zhang 

Voridian Eastman Chemical Company 

Post Office Box 1782 

Columbia, SC 29202 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Ms. Zhang: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by Voridian Eastman Chemical Co. (1560-0008). The purpose of the 

modeling demonstration is to show that the emissions from the BART-eligible source(s) at the 

facility do not cause or contribute 0.5 deciviews or greater visibility impairment in any Class I 

Federal area, thus exempting the source(s) from hrther BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

Voridian Eastman Chemical islare hereby exempt from further BART determinations. SCDHEC 

will include documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

tnasonmr ~r dIicc.sc.po\ . 

Sincerely, 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 1560-0008 

SOUTH C A R O L I N A D E P A R T M E N T OF H E A L T H A N D ENVIRONMENTAL C:ONTROI, 

2600Bull Street * Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 113
BOARD: 

Paul C. Aughtry, IlI 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisner 

Secretary 

PROMOTE PROIECl~ PROSPER 

BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

Glenn A. McCall 

C. Earl Hunter, Commissioner Coleman F. Buckhouse, MD 

I'ramoting andi-,rotectzng the herllth of'the public and the environment 

December 7,2007 

Mr. Eric Dziamniski 

DAK Americas LLC 

3350 Cypress Gardens Road 

Moncks Corner, SC 29461 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Dziamniski: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by DAK Americas LLC (0420-0089). The purpose of the modeling 

demonstration is to show that the emissions fiom the BART-eligible source(s) at the facility do 

not cause or contribute 0.5 deciviews or greater visibility impairment in any Class I Federal area, 

thus exempting the source(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

DAK Americas' facility isfare hereby exempt fiom further BART determinations. SCDHEC 

will include documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

--- masoilnlr rr dht.c.sc.ac~1. 

Sincerely, 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 0420-0089 

SOLI'TH CAK0I.INA DEPARTMENT OF HEALTH AND ENVIKONMEN'TAI, CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 114
BOARD: 

Paul C. Aughrry, I11 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Sreven G. Kisner 

Secrerary 

DHEC 

PROMO1 k urn PKOIFCT PROSPL K 

BOARD: 

Henry C. Scort 

M. David Mitchell, MD 

Glenn A. McCall 

C. Earl Hunrer, Commissioner Coleman F. Buckhouse, MD 

I)rornoti~lg and pt.otecting thr l~ralth oj'thr, pu blir and the rnr 'ii-oizment 

December 7,2007 

Mr. Gary Weinreich 

International Paper Georgetown 

700 South Kaminski Street 

Georgetown, SC 29440 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Weinreich: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by International Paper on behalf of its Georgetown Mill (1 140-0002). The 

purpose of the modeling demonstration is to show that the emissions from the BART-eligible 

source(s) at the facility do not cause or contribute 0.5 deciviews or greater visibility impairment 

in any Class I Federal area, thus exempting the source(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

the Georgetown Mill islare hereby exempt from further BART determinations. SCDHEC will 

include documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

-- 

rnawnrnl- L! dl~ec.hc.co\. 

Sincerely, 

Myra C. Reece, Chief / 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 1140-0002 

SOI'TH C:AROI.lIV.A DEPARTMENT OF HEALTH AN11 EIVl'IRONMEN r.II> CONTROI, 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 115
BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

BOARD: 

Paul C. Aughtry, 111 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisner 

Secretary C. Earl Hunter. Commissioner 

Promoting and protecting the liealtl~ oj the public and the enviror~ment 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

December 7,2007 

Mr. Olden Brooker 

INVISTA - May Plant 

Post Ofice Box 7000 

Camden, SC 29020-7000 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Brooker: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by INVISTA on behalf of its May Plant (1380-0003). The purpose of the 

modeling demonstration is to show that the emissions from the BART-eligible source(s) at the 

facility do not cause or contribute 0.5 deciviews or greater visibility impairment in any Class I 

Federal area, thus exempting the source(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

the May Plant isfare hereby exempt from further BART determinations. SCDHEC will include 

documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

muron[lll. (I dl~ec.sc.~~o~. 

Sincerely, 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 1380-0003 

SOUTH CARO121NA DEPARTMENT OF HEALTH AND EN\'IRONMENTiII, CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 116
BOARD: 

Paul C. Aughtry, 11 I 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisner 

Secretaty 

PROMOTE PKOI'ECT PKOSPER 

BOARD: 

Henry C. Scotc 

M. David Mitchell, MD 

Glenn A. McCall 

C. Earl Hunter, Comm~ssioner Coleman F Buckhouse, MD 

IJyornoting and protecting the health of the pri hlzc and thp envi~onnzent 

December 7,2007 

Ms. Krista Armentrout 

INVISTA - SARL Plant 

Post Office Box 5887 

Spartanburg, SC 29304 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Ms. Armentrout: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by INVISTA on behalf of its SARL Plant (2060-0345). The purpose of the 

modeling demonstration is to show that the emissions from the BART-eligible source(s) at the 

facility do not cause or contribute 0.5 deciviews or greater visibility impairment in any Class I 

Federal area, thus exempting the source(s) fiom further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

the SARL Plant islare hereby exempt from further BART determinations. SCDHEC will include 

documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

mitsonr1lr <I ci~c.sc.gov. 

Sincerely, 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 2060-0345 

SOUTH CAROLINA DEPARTMENT OF HEALTH AND ENVIKONMENTiiL CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 117
BOARD: 

Paul C. Aughrry, 111 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisne~ 

Secretary 

December 7,2007 

PROMOTE PROTECr PROSPER 

C. Earl Hunter, Commissioner 

Prornotzng andprotect~ng t/~e hec~ltl, r!f rh~ptrbl~~ /zrld rlle envtronment 

BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

Mr. Allen Prevatte 

ISG Georgetown 

Post Office Box 6 19 

Georgetown, SC 29442 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Prevatte: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by ISG Georgetown (1 140-0004). The purpose of the modeling 

demonstration is to show that the emissions from the BART-eligible source(s) at the facility do 

not cause or contribute 0.5 deciviews or greater visibility impairment in any Class I Federal area, 

thus exempting the source(s) fiom further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

ISG Georgetown islare hereby exempt from further BART determinations. SCDHEC will 

include documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

!~g~o~~n~r,((dhe..;c:.go\ . 

Sincerely, 

Myra C. Reece, Chief / 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 1 140-0004 

SOUTH C A R O L I N A D E P A R T M E N T OF HEX1,TH AND ENITIRONMENTAL C:ONTROI, 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhecgov 

Appendix J - 118
BOARD: 

Paul C. Aughtry, 111 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisner 

Secretary 

PKOMOTE PKOI'EC1' PROSPER 

BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

Glenn A. McCall 

C. Earl Hunter, Comm~ssioner Coleman F. Buckhouse, MD 

Prorrzotlwg czndprotectlng the h~alth of the publlc and the enl~rronment 

December 7,2007 

Mr. Duane Mumrnert 

Mead Westvaco Corporation, Inc. 

Post Office Box 1 18005 

Charleston, SC 29423 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Murnrnert : 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by MeadWestvaco Corporation, Inc.'s Krafl Division Plant (0560-0008). 

The purpose of the modeling demonstration is to show that the emissions from the BARTeligible source(s) at the facility do not cause or contribute 0.5 deciviews or greater visibility 

impairment in any Class I Federal area, thus exempting the source(s) from further BART 

determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

MeadWestvaco islare hereby exempt from further BART determinations. SCDHEC will include 

documentation to this effect in its final SJP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R Mason of my staff at (803) 898-2230 or 

I~~C\M)IIIII~ (~,clhec.sc.go~ . 

Sincerely, 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 0560-0008 

SOUTH CAROI-INA DEPLAR1'MENT OF HEALTH AND EN\71RONh.IENTAL CONTROI, 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 119
BOARD: 

Paul C. Aughrry. 111 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisner 

Secretary 

BOARD: 

Henry C. Scott 

M. David Mirchell, MD 

Glenn A. McCall 

C. Earl Hunter, Commissioner Coleman F. Buckhouse, MD 

I-'romotii~g and protecting the health oj'zhr p~rblic- iznd tile en~~ir01~rn~~i2t 

December 7,2007 

Mr. Ben Williams 

Milliken & Company 

Post Office Box 8 17 

Inman, SC 29349 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Williams: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by Milliken on behalf of its Dewey Plant (2060-0001). The purpose of the 

modeling demonstration is to show that the emissions from the BART-eligible source(s) at the 

facility do not cause or contribute 0.5 deciviews or greater visibility impairment in any Class I 

Federal area, thus exempting the source(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

Milliken's Dewey Plant isfare hereby exempt from further BART determinations. SCDHEC will 

include documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

1ii11~0111i~r~,,dhec.sc.go\. 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 2060-0001 

BOARD: 

Paul C. Aughrry, 111 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

BOARD: 

Henty C. Scorc 

M. David Mitchell, MD 

Glenn A. McCall 1 

Appendix J - 120
BOARD: 

Paul C. Aughrry, I11 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Sreven G. Kisnrr 

Secretary 

PROMOTE PROIECT PROSP tK 

BOARD: 

Henry C. Scott 

d. David Mitchell, MD 

Glenn A. McCall 

C. Earl Hunter, Commissioner Coleman F. Buckhouse, MD 

J'rorrioti~ig ar~dprotrctir~g the health ($'the public- NIZ~ the r)ti/ironni~nt 

December 7,2007 

Mr. Brian Kellogg 

Owens Coming 

Post Office Box 1367 

Anderson, SC 29622- 1 3 67 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Kellogg: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by Owens Coming (0200-0031). The purpose of the modeling 

demonstration is to show that the emissions fiom the BART-eligible source(s) at the facility do 

not cause or contribute 0.5 deciviews or greater visibility impairment in any Class I Federal area, 

thus exempting the source(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

Owens Corning is/are hereby exempt fiom further BART determinations. SCDHEC will include 

documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

--- 

rn~so~i~iis ~1~~1Iicc'.~c.~o~. 

Sincerely, 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 0200-003 1 

SOUTH (:AROI.INA DEPARTMENT OF HEAII,TH AND ENVIRONMENTrlI, CONTROL 

2600Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 121
BOARD: 

Paul C. Aughtry, 111 

Chairman 

BOARD: 

Henry C. Scott 

Edwin H. Cooper, 111 

Vice Chairman 

Sceven G. Kisner 

Secretary C. Earl Hunter, Commissioner 

Pvovmtrng andpvotectzng the herzlth of tl~e publzc avid the envzvonment 

M. David Mitchell, MD 

Glenn A. McCall 

Coleman E Buckhouse. MD 

December 7,2007 

Ms. Lonnie Gleaton 

Rhodia Charleston 

2 15 1 King Street Extension 

Charleston, SC 29405 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Ms. Gleaton: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by Rhodia Charleston (0560-0011). The purpose of the modeling 

demonstration is to show that the emissions from the BART-eligible source(s) at the facility do 

not cause or contribute 0.5 deciviews or greater visibility impairment in any Class I Federal area, 

thus exempting the source(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

Rhodia Charleston islare hereby exempt from further BART determinations. SCDHEC will 

include documentation to this effect in its final SIP submittal. 

Should you have any fkther questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

n1;iso!itnr (! dl~ec.hc.go~. 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 0560-001 1 

SOUTH C:ARO121NA DEPARTMENT OF HEALTH -AND ENVIRONMENTAI. CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 122
BOARD: 

Paul C. Aughtry, 111 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisner 

Secretary 

December 7,2007 

PKOMOTE PKO1.ECT PROSPER 

C. Earl Hunter, Commissioner 

Promoting nndprotecting tl7r heafti~ of thepnblrr and the environn7rnt 

BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

Ms. Julie Metts 

Santee Cooper 

Post Ofice Box 2946101 

Moncks Corner, SC 2946 1 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Ms. Metts: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstrations for 

exemption submitted by Santee Cooper's Grainger (1340-0003), Jefferies (0420-0003), and 

Winyah (1 140-0005) Stations. The purpose of these modeling demonstrations is to show that the 

emissions from the BART-eligible source(s) at these facilities do not cause or contribute 0.5 

deciviews or greater visibility impairment in any Class I Federal area, thus exempting the 

source(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstrations submitted, SCDHEC concludes that the BART-eligible source(s) at 

Santee Cooper's Grainger, Jefferies, and Winyah Stations islare hereby exempt from further 

BART determinations. SCDHEC will include documentation to this effect in its final SIP 

submittal. 

Should you have any further questions concerning South Carolina's regional haze SP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

ma\onmr ~r dhec.~.co\. ------- 

Sincerely, 

+GZGz~~, ,, Myra C. Reece, Chief JY 

~&au of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit Files Grainger (1 340-0003), Jefferies (0420-0003), Winyah (1 140-0005) 

SOUTH CAKOI.INA DEPARTMENT OF HEALTH AND EN\TIRONMENTXI. CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 123
BOARD: 

Hcnry C. Scott 

M. David MiccheII, MD 

BOARD: 

Paul C. Aughtry, I11 

Chairman 

Edwin H. Cooprr, 111 

Vice Chairman 

Steven G. Kisner 

Secretary C. Earl Huncer, Commissioner 

Promoting ~ndprotectiir~ the heirlth ofthepu6lic nizd the enviroizment 

Glenn A. McCall 

Coleman F. Buckhousr, MD 

December 7,2007 

Mr. Freddie Kinsaul 

Wellman Incorporated 

Post Office Box 100542 

Florence, SC 29501 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Kinsaul: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed 

the Best Available Retrofit Technology (BART) dispersion modeling demonstration for 

exemption submitted by Wellrnan Inc. on behalf of its Palmetto Plant (0820-0013). The purpose 

of the modeling demonstration is to show that the emissions from the BART-eligible source(s) at 

the facility do not cause or contribute 0.5 deciviews or greater visibility impairment in any Class 

I Federal area, thus exempting the source(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, this 

information was shared with the U.S. Environmental Protection Agency as well as the Federal 

Land Managers for review and comment. 

Based on the demonstration submitted, SCDHEC concludes that the BART-eligible source(s) at 

Wellman Inc.'s Palmetto Plant islare hereby exempt from further BART determinations. 

SCDHEC will include documentation to this effect in its final SIP submittal. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please contact Maeve S.R. Mason of my staff at (803) 898-2230 or 

m;g)nmr (r,dliecsc.~o~. 

Sincerely, 

Myra C. Reece, Chief 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brown, Jr., Director, Division of Air Planning, Development and Outreach, 

SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Permit File 0820-00 13 

--- SOu TH CAROLINA DEP-ARTMEIVT OF HEALTH ----- 

AND ENVIRONMENTAI. CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 124
BOARI): 

Paul C. Auphrry. 111 

Chairlndn 

Edwin H. (:oopcl-, I11 

Vice Chairm:~n 

December 12,2007 

Mr. Glenn Brannen 

SCE&G 

6248 Bush River Road 

Columbia, SC 292 12 

Re: Regional Haze Exemption from Best Available Retrofit Technology (BART) 

Dear Mr. Brannen: 

The South Carolina Department of Health and Environmental Control (SCDHEC) has reviewed the Best 

Available Retrofit Technology (BART) dispersion modeling demonstrations for exemption submitted by 

SCE&G's Canadys (0740-0002), Wateree (1900-001 3), and Williams (0420-0006) Plants. The purpose 

of these modeling demonstrations is to show that the emissions from the BART-eligible source(s) at these 

facilities do not cause or contribute 0.5 deciviews or greater visibility impairment in any Class I Federal 

area, thus exempting the source(s) from further BART determination. 

Consistent with the regional haze state implementation plan (SIP) guidance documents, these 

demonstrations were shared with the U.S. Environmental Protection Agency (EPA) as well as the Federal 

Land Managers for review and comment. 

Based on the demonstrations submitted, SCDHEC concludes that the BART-eligible source(s) at 

SCE&G's Canadys were found to contribute less than 0.5 deciviews to visibility impairment and are 

therefore exempt from further BART determinations. The BART-eligible source(s) at SCE&G Wateree 

and Williams Plants, while determined to cause or contribute to greater than 0.5 deciviews at Cape 

Romain, were also determined to be exempt from further analysis based on their participation in the 

State's Clean Air Interstate Rule (CAIR) trading program. SCDHEC will include documentation to this 

effect in its final SIP submittal to EPA. No additional action related to BART is required of SCE&G for 

the noted facilities at this time. 

Should you have any further questions concerning South Carolina's regional haze SIP development, 

please contact Maeve S.R. Mason of my staff at (803) 898-2230 or maso~~mr!~dhe~.~~.gov. 

Sincerely, 

Myra C'. Reece. Chief bBureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Robert J. Brow11, Jr., Director, Division of Air Planning, Developn~ent and Outreach. 

SCDHEC 

Stacey Gardner. Manager, Regulation Develop~ne~it Section. SC'DHEC' 

Pat Brekber, Vl STAS Technical Ad\ isor 

Permit Files - Canadys (0730-0002). Wateree ( 1900-001 3). Williams (0320-0006) 

Appendix J - 125
ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP 

TROUTMAN SANDERS BUILDING 

1001 HAXALL POINT 

RICHMOND. VIRGINIA 23219 

www.lroulmansanders.~om 

TELEPHONE: 804-697-1200 

FACSIMILE. 804-697-1339 

MAILING ADDRESS 

P.O. BOX 1122 

RICHMOND. VIRGINIA 23218-1122 

John R. Cline 

john.cline@troutmansanders.com 

Via US. Mail and Electronic Mail 

Ms. Maeve S. R. Mason 

Regulatory Development Section 

Bureau of Air Quality 

2600 Bull Street 

Columbia, South Carolina 29201 

Direct Dial: 804-697-1265 

Direct Fax: 804-698-51 34 

December 3,2007 

Re: Regional Haze SIP 

Dear Ms. Mason: 

On behalf of the Southeast Visibility Industry Coalition or "SEVIC," I am pleased to 

submit comments on the State's pre-hearing draft Regional Haze SIP.' SEVIC consists of a 

group of electric utility and industrial companies with facilities throughout the southeastern U.S. 

which may be subject to requirements of the regional haze rule. For several years now, the 

Coalition has monitored the planning and analyses of VISTAS, participated in various VISTASstakeholder meetings and conference calls, and commented not only on various work products of 

VISTAS but also on EPA regulations and guidance related to regional haze. 

SEVIC first wants to compliment the VISTAS staff and participants fi-om the various 

States, in general, and South Carolina, in particular. The multi-year regional planning process 

was technically and scientifically complex as well as comprehensive. With the significant 

number of VISTAS participants and other stakeholders, communications were a major challenge. 

Yet, for the vast majority of activities, SEVIC members had ready access to the necessary 

information and documents fi-om VISTAS, and the VISTAS representatives were accessible and 

1 SEVIC's comments were based upon a pre-hearing draft version of the SIP dated August 10, 2007, before a subsequent version 

of the draft SIP dated November 9,2007 was posted on SCDHEC's website. As such, the page and paragraph numbers identified 

herein may not match precisely with the locations of the referenced subject matter in the later version. 

ATLANTA HONG KONG LONDON NEW YORK NEWARK - NORFOLK - RALEIGH 

RICHMOND - SHANGHAI - TYSONS CORNER - VIRGINIA BEACH - WASE-IINGTON, D.C. 

Appendix J - 126
TROUTMAN SANDERS LLP 

ATTORNEYS A T L A W A LlMlTED IIABILITI PARTNERSHIP 

Ms. Maeve S. R. Mason 

December 3,2007 

Page 2 

responsive. We believe the highly capable leadership of Renee Shealy was instrumental in the 

competence and effectiveness of the VISTAS program. 

SEVIC also believes that SCDHEC's extensive participation in VISTAS is reflected in 

the high quality of the subject draft SIP. Although the Coalition has comments on the SIP 

contents to be sure, SCDHEC is commended for preparing a plan that addresses the State's 

myriad requirements and responsibilities under the Clean Air Act and its implementing 

regulations and guidance. 

SEVIC cannot overestimate the precedential nature of South Carolina's draft regional 

haze SIP. The subject plan undoubtedly will serve as a template and benchmark for periodic 

revisions which South Carolina will be making to its regional haze SIP. Moreover, because 

South Carolina is one of the first VISTAS States to release its draft SIP for public review and 

comment, those other States undoubtedly will be closely monitoring South Carolina's SIP and 

the issues raised during the public comment process. Given that perspective, SEVIC first 

scrutinized major portions of the main body of that SIP. Thereafter, we have prepared the 

enclosed comments on numerous details therein which have the potential for affecting its 

members, not only in the current rulemaking but also in future revised SIPS to come, either by 

South Carolina or by another VISTAS State. 

In terms of "bottomline" results, SEVIC believes that the ultimate decisions in 

SCDHEC's regional haze SIP regarding possible control measures are correct and appropriate 

for this current planning period. The State's findings and conclusions with respect to BART and 

reasonable progress reflect informed and well-reasoned analyses which fit comfortably with the 

fundamental mandates of the Clean Air Act as well as requirements and guidance of EPA. The 

administrative record to support those findings and conclusions appears to be, for the most part, 

documented and complete. With regard to this latter issue, SEVIC encourages the State to give 

priority to the sufficiency of that administrative record in order to help insulate it from a 

procedural challenge. 

Because of SEVIC's participation throughout the VISTAS process, South Carolina's 

regional haze contacts are aware of many of our positions on fundamental issues. First and 

foremost, we strongly believe that Congress delegated substantial authority to each State for it to 

decide what measures are appropriate to achieve its share of visibility improvements in affected 

class I areas. In that respect, it is vitally important to distinguish between federal regulation and 

guidance, because generally the force of law is considerably less with the latter. Second, in 

weighing the statutory factors for either BART or reasonable progress analysis, SEVIC believes 

the Act commands proper consideration and accountability of the visibility improvement 

attendant to any candidate control measure. For example, contrary to a common misconception, 

Appendix J - 127
TROUTMAN SANDERS LLP 

ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP 

Ms. Maeve S. R. Mason 

December 3,2007 

Page 3 

section 169A says absolutely nothing about determining a "reasonable control measure"; the 

State must determine "reasonable progress," i.e., reasonable visibility improvement. 

SEVIC's primary interest in South Carolina's SIP is how SCDHEC interprets and applies 

the emission control provisions of BART and reasonable progress to individual sources. For that 

reason, the bulk of the Coalition's comments focus on such issues. We do, however, raise 

questions in the attached comments regarding certain assumptions and inputs used by VISTAS. 

Some of those questions go to whether the particular assumption or input was appropriate; other 

questions basically seek clarification and/or further explanation. In addition, the sheer volume of 

the documentation in the Appendices prevents SEVIC from reviewing and commenting on each 

of those documents. However, because we expect that the major issues have been addressed 

within the main body of the SIP, SEVIC intends for our comments on those issues to apply 

equally to how they are discussed within any of the Appendices. 

Finally, the State's analyses for BART and reasonable progress in this particular SIP 

were not particularly demanding due in large part to the substantial visibility improvements to be 

achieved by other (non-regional haze) CAA programs. As a result, SCDHEC's consideration of 

some statutory factors was highly generalized. Although SEVIC understands why such analyses 

were not exhaustive, the Coalition has concerns with the precedent that approach may establish 

for subsequent regional haze SIPS. Consequently, our comments include in several places a 

request for a more expansive discussion or explanation of certain factors and other criteria 

related to statutory and regulatory requirements. Because this initial SIP establishes a 

benchmark and consists of a likely template for many future evaluations, SEVIC believes this 

SIP should contain adequate discussion of South Carolina's understandings of, and views on, 

those issues. 

SEVIC appreciates this opportunity to comment on the State's draft regional haze SIP. 

Although those comments address the Coalition's primary interests at this time, we reserve the 

right to file supplemental and/or additional comments before the close of the public comment 

period. Should you have any questions about the enclosed comments, please do not hesitate to 

contact me. 

Phn R. Cline 

Enclosure 

Appendix J - 128
Comments of SEVIC 

on the 

South Carolina Draft Regional Haze SIP' 

SEVIC's comments herein on South Carolina's draft regional haze SIP have been 

organized into two sections. In Section I, SEVIC responds to the State's treatment of a variety of 

substantive issues. Included within the issues addressed in this section of SEVIC's comments 

are, for example, concerns about (1) the State's interpretation and/or representation of 

fundamental statutory requirements, (2) the specific inputs and assumptions for particular 

analyses described in the SIP, and (3) the general lack of substantive explanations of the overall 

intended purpose, scope and contents of the available framework for determination of either 

BART or reasonable progress. 

This original regional haze SIP will serve as a template for future regional haze 

requirements when South Carolina must revise the SIP for each successive planning period. 

Therefore, SEVIC believes this initial SIP must lay the appropriate groundwork for those SIPS 

which follow. Although as discussed herein, SCDHEC is able to justifi its abbreviated 

reasonable progress analyses for this particular planning period, this SIP should do a much better 

job of explaining the overall statutory framework for reasonable progress, how each statutory 

factor must be considered and weighed relative to the other factors, that visibility improvement is 

an integral consideration when determining reasonable progress, and that States have been 

delegated considerable flexibility when making those determinations. In other words, SEVIC 

strongly believes that the underlying basis for consistent and thorough future determinations of 

reasonable progress should be established within the State's original regional haze SIP. 

Section I1 of SEVIC's comments addresses particular areas where we believe the State's 

descriptions of particular requirements, analyses or results are either misleading or incomplete. 

The regional haze program is a comprehensive and complex set of requirements where specific 

terms have specific meanings. Consequently, care must be exercised when paraphrasing and/or 

explaining such requirements, because a different word or term may not reflect the actual 

meaning or intent of either the Act or the regulations. In this second section of its comments, 

SEVIC primarily addresses specific statements in the State's draft SIP which we believe should 

be revised to more accurately describe the particular subject matter. 

SECTION I 

Page Comment 

2, last 7 1 " sentence: SEVIC recommends re-stating this as follows: "In developing the 

SIP, South Carolina has prepared a long-term strategy and examined the possible 

I These comments were based upon a pre-hearing draft version of the SIP dated August 10,2007, before a 

subsequent version of the draft SIP dated November 9,2007 was posted on SCDHEC's website. As such, the page 

and paragraph numbers identified herein may not match precisely with the locations of the referenced subject matter 

in the later version. 

Appendix J - 129
12, 3'd 7 

12, last 7 

14, last 7 

15, last 7 

application of BART in order to establish reasonable progress goals for Cape 

Romain." 

2"d sentence: "The State may not adopt a reasonable progress goal that represents 

less visibility improvement than is expected to result from implementation of 

other requirements of the CAA during the applicable period." 40 CFR 

51.308(d)(l)(vi). Visibility improvement achieved with the uniform rate of 

progress is r26.48 - 23.15 =] 3.3 dv. Visibility improvement expected to result 

from other CAA programs is r26.48 - 22.72 =] 3.8 dv. Consequently, the 

reasonable progress goal for 201 8 must be at least 3.8 dv. 

5'h line: End this sentence after the word "State". A State is not required to 

identify the uniform rate ofprogress for any class I area located outside that State. 

3'd line: After the words "each Class I area", add the words "in that State." 

1" line: BART is not a specific component of each State's first LTS. The plain 

language of 5 169A(b)(2) makes clear that BART and the LTS are SIP "measures 

as may be necessary to make reasonable progress toward the national goal." 

Last part of sentence: 40 CFR Section 5 1.308(i) does not require consultation 

between the States and the FLM "on the implementation of other programs having 

the potential to contribute to impairment of visibility in any mandatory Class I 

Federal area within the State." 

6'h line: After the words "Source contributions", add the words "to visibility 

impairment" and delete the word "to". 

The subject goal is that of the Clean Air Act, not the RHR. 

SEVIC questions whether one of IMPROVE'S objectives is "to identify emission 

sources responsible for man-made visibility impairments". 

Last line: Replace the words "reductions committed to in the SIP" with 

"reasonable progress goals of this SIP." 

1" line: Replace the word "states" with "each State" 

3'd line: Delete the remainder of the sentence beginning with "as well as for each 

mandatory . . .". A State is not required to make such a demonstration for a class 

I area outside of that State. 

lSt line: After the words ". . .Class I Federal area", add the words "in that State". 

5' line: Does the reference here to "fire emissions" apply only to wildland fires 

or rather to all fire types? What are the implications for the State's determination 

Appendix J - 130
of contributors to Cape Romain visibility impairment that "fire emissions remain 

the same for air quality modeling in both the base and any future years"? 

32, 4th 7 2nd sentence: SEVIC believes this is too abbreviated to adequately explain 

DHEC's point. Concluding with the phrase "which is used to determine 

reasonable progress" appears to be a gross over-generalization. 

50, lSt7 SEVIC recommends the beginning of this paragraph be re-written as follows: 

"As stated in section 1.3, the RHR requires a State's SIP to establish reasonable 

progress goals (RPGs) for each Class I area in the State. This first set of RPGs 

must be met by emission reductions required by other CAA programs, by any 

BART requirements and by measures in States' long-term strategies . . ." 

51, 3'd7 Last sentence: If NOx emissions for EGUs were capped at 2007 levels, how were 

the NOx emission reductions from future CAA programs, such as CAIR, 

accounted for? 

58, 2nd 7 3'd line: The end of the affected sentence should read: ". . . better than the areas' 

respective uniform rates of progress." 

58, 2nd 7 Last sentence: SEVIC recommends re-stating this as: "This means that the 

amount of visibility improvement is at least 10 percent greater than the visibility 

improvement that would be achieved in 20 18 with Cape Romain's uniform rate of 

progress." 

64 Section 7.4, Relative Contributions: SEVIC requests SCDHEC to discuss, within 

this section, the rationale for this analysis relying upon projected 2009 emissions 

instead of projected 201 8 emissions. According to the discussion in the first 

paragraph of this section, emission sensitivity runs were initially performed using 

"the initial 201 8 projections inventory." For identifying possible, new control 

measures to achieve reasonable progress, it seems that the appropriate reference 

for any sensitivity analysis should have been projected 2108 emissions that 

account for emission reductions from other CAA programs. Nevertheless, the 

analysis reported in this section used modeled visibility associated with 2009 

emissions as the baseline for comparison. In doing so, VISTAS did not account 

for the substantial changes in emissions which will be occurring in the 2010-2018 

timeframe due to major national programs such as CAIR and CAMR as well as 

other CAA programs. Please explain why this analysis was not based on the 

modeling runs using the 201 8 emissions inventory and discuss the relative 

uncertainty or error resulting from use of 2009 emissions. 

SEVIC understands the discussion in this section to mean that determinations of 

the relative contributions of different pollutants from different States to visibility 

impairment at Cape Romain were based on modeling results for either 5 or 6 davs. 

Those determinations are summarized on page 65. If SEVIC's understanding is 

Appendix J - 131
correct, then SCDHEC is requested to comment on the degree of uncertainty in its 

determinations of the relative contributions of different pollutants from different 

Stateshegions. SEVIC believes that the credibility of those determinations may 

be in doubt because (1) the modeled emissions were arguably the wrong ones to 

use, and (2) the modeling results were extremely limited in number. 

66, 2nd 7 Last sentence: This is no basis for this conclusion fiom the preceding discussion. 

SEVIC believes that information which may support this conclusion is provided 

on page 21, i.e., that ammonium nitrate formation in the VISTAS region is limited 

by ammonia concentrations. 

66, 3rd 7 Last sentence: SCDHEC asserts that "[rleducing primary carbon from point 

sources, ground level sources, and fires are projected to have almost no visibility 

benefit at Cape Romain." Yet, when determining back trajectories, SCDHEC 

states on page 69 that "[elach back trajectory was weighted by sulfate extinction 

for that day, allowing for focus on the 20 percent worst days that are influenced 

by sulfate and placing less importance on days influenced by organic carbon or 

fires." 

These two sentences appear to be in conflict. In particular, the latter sentence 

above strongly suggests that some of Cape Romain's worst days may be 

influenced by organic carbon or fires. SEVIC requests SCDHEC to provide 

further analysis concerning the relative impact of organic carbon or fires upon 

visibility in Cape Romain, especially in 201 8 when the percentage of total 

emissions attributable to organic carbon or fires is expected to be relatively higher 

due to pending major reductions of SO2 and NOx emissions from the CAIR. 

SEVIC again recognizes that SCDHEC's conclusion regarding the dominance of 

sulfate on Cape Romain's visibility is based upon analyses using 2009 emissions, 

before the significant visibility improvements associated with CAIR's SO2 and 

NOx reductions. SEVIC again questions how the degree of sulfate's dominance 

would change if the relative contributions to visibility impairment had been based 

on 201 8 emissions. SCDHEC is requested to evaluate and discuss the uncertainty 

arising from its analysis of "relative contributions" with 2009 emissions. 

67 Sections 7.5.1 & 7.5.2 - Back Trajectory Analyses & Residence Time Plots: 

Defining the most likely central path of air masses that arrive at Cape Romain was 

based upon the 20% worst days baseline of 2000-2004. The relatively time 

periods that those dominant winds influenced Cape Romain on those 20% worst 

days during 2000-2004 were then determined. However, SEVIC believes that 

such back trajectory and residence time analyses would have been more 

appropriately defined by the 20% worst days in 201 8. DHEC is requested to 

comment on why it chose to define back trajectories and residence times based 

upon impacts associated with historical emissions which are not representative of 

the relative impacts expected at Cape Romain from emissions in 201 8. 

Appendix J - 132
Section 7.5.3 - SO2 Areas of Influence: It appears that a SO2 Area of Influence 

(AOI) for a class I area is defined as "the geographic area with highest probability 

of influencing the [class I area] on the 20 percent worst days in 2000-2004 that 

were dominated by sulfate." However, SEVIC believes that the ultimate analysis 

is intended to define the area containing emissions in 201 8 which are expected to 

have the highest probability of influencing the class I area. Please explain how 

the 20% worst days in 2000-2004 (resulting fiom SO2 emissions in 2000-2004) 

translates into determining the greatest contributors to class I areas in 20 18. 

Please also (1) explain why sulfate extinction weighted residence times for 

identifying a class I area's A01 were not determined with 20 18 SO2 emissions 

and historical meteorological back trajectories, and (2) comment on the likely 

differences between AOIs determined by that latter method and the AOIs 

identified by the VISTAS method with an underlying basis on 2000-2004 SO2 

emissions. 

Figures 7.5.4- 1 and 7.5.4-2: Although these plots refer to "20 18 emissions," are 

they nevertheless also based upon sulfate-extinction-weighted residence times 

determined from the 20% worst days of visibility due to sulfate during 2000-2004? 

If so, does this not mean that the sulfate portion of the "weighting" is heavily 

influenced by SO2 emissions which will not be present in 20 18? 

74, last 1 1" line: Unfortunately, as discussed further herein, there appears to be a 

widespread misconception that the so-called "four-factor analysis" is used to 

identify reasonable control measures. The plain words in the statute, however, 

say otherwise. The four factors must be considered in determining whether 

visibility improvement achieved by a candidate control measure will be 

reasonable. SEVIC is concerned that South Carolina's draft SIP does not 

appropriately describe the intended interrelationship among reasonable visibility 

improvement and the other four statutory factors. See 42 U.S.C. fj 7491(g)(1) ("In 

determining reasonable progress . . ."). 

SEVIC recommends that this sentence be revised to read as follows: "These 

analyses indicated that SC should consider whether any additional control 

measures for certain coal-fired utility and industrial boilers could achieve any 

reasonable progress." 

Recognizing that the "master spreadsheet" is rather complex and thus difficult to 

describe, SEVIC believes a copy of the first page of Cape Romain's spreadsheet 

should be included in this portion of the document for ease in understanding what 

it contains. 

Section 7.7: First, SEVIC recommends that the title of this section should be 

restated as: "Which Control Measures for Individual Sources Achieve Reasonable 

Progress". 

Appendix J - 133
Second, SEVIC believes that this section is out of place in its current location. 

We suggest that a more appropriate location for this section would be in the 

Chapter 8.0 discussion of reasonable progress. Therefore, SEVIC's comments on 

the current contents of pages 76-78 are provided later herein with the remainder 

of our comments on reasonable progress. 

78, last 7 1" line: SEVIC disagrees with the characterization of the directive under section 

169A that States must assess "older" emission sources. When section 169A was 

adopted, Congress specifically limited the application of BART only to certain 

existing major (not "larger") sources no older than 15 years-old, that had just 

missed applicability of the new PSD program for new major sources. The fact 

that it has taken 30 years for the States to implement that directive explains why 

the BART-eligible sources are now relatively "old." 

5th line: The statute (CAA 7 169A) actually "directs states to include BART in 

their regional haze SIPS." 

79, 4th 7 This discussion does not accurately describe the plain language of the statute. 

The referenced section requires five explicit factors to be considered when 

determining BART. To say that "states should also consider the degree of 

improvement in visibility" is simply wrong; States must consider visibility 

improvement resulting from any candidate BART measure. 

1" sentence: SEVIC does not believe that the subject exemption is a discretionary 

action on the part of South Carolina. If a source is not found to cause or 

contribute to visibility impairment, then, by definition, it cannot be subject to 

BART. 

80, last 7 lSt sentence: This statement is too general and vague. DHEC should provide a 

brief statement that of the 2 1 BART-eligible sources in the State, only 2 were 

determined to be subject to BART because each of those latter sources' modeled 

impacts at Cape Romain was higher than the minimum level which defines a 

contribution to visibility impairment. After that explanation, DHEC should 

indicate that Figure 7.8.2-1 illustrates those modeling results. (In that regard, the 

parameter "Impact (Change in dv)" in that figure needs to be definedlexplained in 

the text.) 

Reasonable Progress -- General Comments 

Earlier sections of Chapter 7 describe the detailed analytical process for identifying the 

scope of South Carolina's "four-factor" reasonable progress analyses. For each source identified, 

SCDHEC must now determine whether the visibility improvement ("progress") resulting from 

the application of any control measure on that source would be reasonable. As the statute 

requires, that determination must consider four specific factors. 

Appendix J - 134
The State's reasonable progress analyses consist of the initial discussion of reasonable 

progress at section 7.7 (pages 76-78) together with the subsequent "four-factor analyses" in 

section 8.1 (pages 94- 103). SEVIC recommends that those discussions be consolidated and 

placed after the discussion of the State's BART analyses and conclusions. 

As discussed later herein, SEVIC has comments on several matters within the State's 

reasonable progress analyses. Although we find the overall reasonable progress analyses to be 

rather abbreviated, SEVIC nevertheless believes the extent of those analyses is acceptable for 

this particular planning period. SEVIC also concurs with the State's conclusions that adding 

SO2 control measures to any of the candidate sources would not achieve reasonable progress 

during the current planning period. 

Having said that, however, SEVIC believes that SCDHEC's description of the overall 

statutory analysis and the explanation of the individual factors are insufficient and therefore 

unacceptable for an initial regional haze SIP. If the nature of the particular SIP were different, 

i.e., a rulemaking for a one-time issue, then SEVIC's opinion could be different. But, in this 

instance, the regional haze SIP will be revised at established 10-year intervals after 20 18, and it 

will be reviewed periodically during each interim planning period. Therefore, because South 

Carolina's regional haze SIP will be a "living document" for the next fifty-plus years, SEVIC 

believes that it is critically important for the initial version of that document to establish a clear 

and complete foundation upon which future revisions may build. Accordingly, the comments 

that follow apply to SCDHEC's descriptions of the reasonable progress analysis in the main 

body of the SIP as well as in the SIP Appendices. 

Of foremost importance with respect to reasonable progress, SEVIC believes that this SIP 

must acknowledge the fundamental role of visibility improvement in any statutory analysis. The 

plain language of the statute expresses the legislative intent as follows: 

[I]n determining reasonable progress there shall be taken into 

consideration [l] the costs of compliance, [2] the time necessary for 

compliance, [3] the energy and nonair quality environmental impacts 

of compliance, and [4] the remaining useful life of any existing source 

subject to such requirements. 42 U.S.C. $ 749 1 (g)(l) (emphasis 

added). 

In the above context, the word "progress" is nothing more than a synonym for "visibility 

improvement." Thus, Congress directed the States to consider four specific factors in 

determining whether visibility improvement is reasonable. That is, the analytical methodology is 

not unlike that for BART where a candidate control measure is evaluated in terms of five factors. 

Consideration of the related visibility improvement during any reasonable progress "four-factor 

analysis" is simply intuitive, common sense.2 An analysis based solely on evaluating four 

statutory factors without considering visibility improvement is completely meaningless in the 

--- 

"[Ilt is self evident that visibility improvement must be considered in determining what progress is reasonable in 

remedying visibility impairment." EPA, Draft Guidance for Setting Reasonable Progress Goals Under the 

Regional Haze Program, § 5.0, p. 1 (Nov. 28,2005). 

Appendix J - 135
context of the congressional goal, i.e., visibility improvement to natural background levels in 

class I areas. 

Clearly, future regional haze SIPS for later planning periods will be called on again to 

determine reasonable progress considering the statutory factors. For that reason, SEVIC strongly 

requests SCDHEC to address the critical importance of visibility improvement in any reasonable 

progress analysis with the statutory factors. In terms of appropriate placement within the 

discussion of reasonable progress, SEVIC suggests that the inherent relationship between 

visibility improvement and the statutory factors should be discussed immediately preceding 

discussion of the individual statutory factors. 

Because the State's initial regional haze SIP should serve as a template for future 

revisions of that SIP, SEVIC believes that SCDHEC's discussion of the individual statutory 

factors must be supplemented considerably, as follows: 

(1) Costs of compliance: "Cost-effectiveness" is one obvious, and important, element in 

the assessment of this factor. However, reducing an analysis of this statutory factor to nothing 

other than the $ per ton of SO2 removed for a candidate control measure constitutes, in most 

circumstances, a major flaw in the reasonable progress analysis. In the case of the currently 

proposed SIP, however, SEVIC believes that such a limited assessment likely is sufficient 

because the $/ton cost-effectiveness of each candidate control measures was higher than the 

range of such costs which SCDHEC had established as representative of controls which achieve 

reasonable progress. The State, of course, has discretion in how it weighs its analysis of the 

statutory factors. 

Cost-effectiveness, measured in terms of dollars per unit of visibility improvement, can 

be a much more meaningful metric for the reasonable progress analysis.3 Indeed, a highly 

informative assessment would rank-order the values of $/dv for various candidate controls from 

the lowest to the highest value. Should additional visibility improvement be necessary to attain 

reasonable progress in a planning period, then clearly the more cost-effective measures (lower 

$/dv) would be better candidates with respect to this statutory factor. 

- There are at least 2 different ways to express this $/dv metric. One approach would be 

on an individual class I basis only, where visibility improvement by a candidate control measure 

is evaluated only with respect to that area. Of course, all other things being equal, a State would 

look to maximize the benefits of any reasonable progress costs. Thus, because sources may 

contribute to visibility impairment in multiple class I areas, the aggregate visibility improvement 

achieved in all affected class I areas by a candidate control measure at a source could be 

calculated, and the resultant comparisons among $ per aggregate dv improvement would be 

made. 

The control costs associated with other concurrent CAA programs constitute another 

barometer for assessing the appropriate level of control costs to improve visibility. In particular, 

a principal reason why visibility improvements from those other CAA programs are so attractive 

EPA, Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program, 5-1 (June 1,2007) 

(hereinafter "Reasonable Progress Guidance"). 

Appendix J - 136
is that they come at zero costs to the regional haze program. From that perspective, visibility 

improvement achieved with substantial control costs attributable solely to regional haze will be 

more difficult to regard as reasonable progress. 

EPA's final reasonable progress guidance expressly notes that the costs-ofcompliance factor may encompass "the implication of compliance costs to the health and vitality 

of industries within a state.'' The Agency's position reinforces its well-settled view that each 

State has considerable discretion as to how it weighs the statutory factors in a reasonable 

progress analysis. As EPA has explained: 

[l'lhe visibility regulations gives the States a great deal of flexibility 

in determining the measures they choose to assure reasonable progress 

toward the national goal. As the Act requires, EPA has provided 

measures for the States to consider, but left the actual 'mix' of 

measures adopted to the States' di~cretion.~ 

At page 1-4 of its Reasonable Progress Guidance, EPA also acknowledges the flexibility 

which States have in their reasonable progress planning, as follows: 

In deciding what amount of emissions reduction is appropriate in 

setting the RPG, you should take into account the fact that the longterm goal of no manmade impairment encompasses several planning 

periods. It is reasonable for you to defer reductions to later planning 

periods in order to maintain a consistent glidepath toward the longterm goal. 

In other words, SCDHEC should not feel compelled to weigh the statutory factors in such 

a manner as to require substantial emission reductions in order to maximize visibility 

improvement achieved by 20 18 or in any other planning period. 

SEVIC clearly recognizes the ever-present tension between environmental protection and 

economic growth and stability. As EPA guidance suggests, however, SCDHEC's ultimate 

reasonable progress decision is encouraged to qualitatively account for the economic impacts of 

that decision not only upon the facility's continued vitality but also upon the economic wellbeing of its employees and the surrounding community. 

(2) Time Necessary for Compliance: Consistent with its belief that the content and format of 

this initial regional haze SIP will serve as the benchmark for contents and formats of succeeding 

SIP revisions, SEVIC believes that SCDHEC's discussion of this statutory factor should be more 

specific. In particular, during the initial planning period, consideration of the time necessary for 

compliance must account for the major influence of SO2 compliance plans required by EPA's 

CAIR. Indeed, the questionable availability of sufficient boilermakers and other skilled 

Id. 5- EPA, Summaly of Comments and Responses on the May 22, 1980 Proposed Regulations for Visibility Protection 

for Federal Class IAreas, 172 (Oct. 1980). 

Appendix J - 137
craftsmen weighed heavily in EPA7s decision to structure that emissions-control program in two 

phases, beginning in 20 10 and 20 15, respectively. 

Due to the overwhelming number of utility installations of retrofit SO2 controls projected 

through 2015, availabilities of those controls for other source categories are expected to be 

limited. Even if a sufficient number of retrofit SO2 controls were available for other-than-CAIR 

programs, there is still the question whether sufficient, skilled construction personnel would be 

available prior to 20 15. 

Therefore, while fuel-switching could theoretically be implemented in 2-3 years and postcombustion SO2 controls could theoretically be installed in 3+ years, SEVIC suggests that 

SCDHEC7s discussion of this factor should acknowledge how unlikely those timeframes are for 

this particular SIP in light of the major equipment and labor demands of the CAIR throughout 

much of the first planning period. As a result, consideration of this factor only strengthens 

SCDHEC7s ultimate conclusions from its reasonable progress analyses of individual sources. 

(3) Enerm and Non-Air Oualitv Environmental Impacts: In terms of identifying the scope 

and magnitude of various elements to be considered with this statutory factor, SEVIC believes 

the current discussion is very deficient. SCDHEC's (VISTAS'S) analyses went to great lengths 

to identify possible retrofit SO2 control technologies, their control efficiencies and their related 

costs. However, it appears that no comparable identification and evaluation protocol was 

established to account for energy and environmental impacts of those technologies. 

In this particular SIP, the scope of candidate SO2 control technologies was reduced to 

those technically feasible for coal-fired utility and industrial boilers. In spite of this very 

manageable number of source categories and potential control measures, SCDHEC apparently 

did not prepare any "master lists" of energy impacts and environmental impacts and then 

characterize the likely ranges of those impacts. 

When candidate control measures were evaluated for an individual source, the relative 

amounts of expected SO2 emission reductions were identified for those measures. Thus, in 

terms of the relative amounts of those SO2 reductions and the relative sizes of the individual 

sources, a summary presentation of the energy and environmental impacts from each candidate 

control as applied to each individual source would provide an informative means for comparing 

those impacts. SEVIC believes that SCDHEC should amend this section to, at a minimum, 

identify and characterize the ranges of energy and environmental impacts expected from the 

various candidate control measures which were considered for the different sources. The 

regulated community needs certainty, and any demonstration of what specific energy and 

environmental impacts may be examined for candidate SO2 control measures during the next 

SIP-planning period will help affected sources and SCDHEC alike to structure such future 

analyses. 

(4) Remaining Useful Life: SEVIC believes that SCDHEC7s discussion of this statutory 

factor is likewise very deficient. Although the factor does not play a significant role in any 

reasonable progress analysis by SCDHEC in this SIP, the SIP nevertheless fails to provide any 

meaningful description of what elements might be evaluated when considering that factor. 

Appendix J - 138
EPA considers this particular statutory factor to be little more than one element of the 

cost-of-compliance analysis. Accordingly, EPA suggests that "[ilf the remaining useful life of 

the source will clearly exceed this time period [for amortizing the cost of a control device], the 

remaining useful life factor has essentially no effect on control costs and on the reasonable 

progress determinati~n."~ SEVIC respectfully disagrees with EPA's limited view of this 

statutory factor. 

As an initial matter, it is highly unlikely that Congress intended the "useful life" factor to 

be nothing more than part of the "cost-of-compliance" factor. If that were the only intended 

purpose of the "useful life" factor, it is reasonable to expect that Congress would never have 

expressly and separately identified that parameter. 

Furthermore, the legislative history of section 169A of the 1977 Amendments to the Act 

indicates that Congress was very reluctant to require the widespread retrofitting of control 

equipment on existing sources. During those Amendments, Congress adopted the PSD program, 

requiring best available control technology on new and modified major sources. In doing so, 

Congress deliberately "grandfathered existing major sources, concluding that the imposition of 

substantial costs for new control equipment on existing units did not constitute sound public 

policy. 

Nevertheless, when adopting the visibility protection provisions of the '77 Amendments, 

Congress did carve out a subset of existing major sources for which best available retrofit 

technology might be required. The legislative history of those visibility provisions confirms that 

potentially BART-eligible sources were restricted to those which began operation between 1962 

and 1977 because Congress did not want to require those expensive retrofits on units that were 

more than 15-years-old. In other words, SEVIC believes that "remaining useful life" is a distinct 

statutory factor because Congress did not favor a requirement for retrofit controls on sources 

greater than 15-years-old. 

Application of the statutory factors does not lend itself to a completely objective and 

quantitative analysis. The "remaining useful life" factor is a case in point. While the visibility 

provisions of the Act do not prohibit the requirement of retrofit controls on any unit of a certain 

age or older, SEVIC believes that the legislative histories and structures of those provisions and 

the PSD program evince congressional sentiment not to require control measures on existing 

major sources, in general, and on existing major sources over 15-years-old, in particular, 

During this SIP-planning period, the "remaining useful life" factor did not significantly 

influence SCDHEC's reasonable progress analyses because consideration of compliance costs 

weighed so heavily against requiring any SO2 control measures. However, during future 

revisions to its regional haze SIP, this statutory factor may require more consideration as 

candidate sources become even older than they currently are. 

EPA, Reasonable Progress Guidance, 5-3. 

Appendix J - 139
Reasonable Proaresss -- Specific Comments 

In the preceding discussion, SEVIC has outlined its general concerns with South 

Carolina's regional haze SIP and the need to address more details of the purpose, scope and 

content of the reasonable progress analysis in order that subsequent analyses share consistent 

regulatory frameworks and related policies. Against that fundamental background, SEVIC offers 

the following specific comments on individual components of SCDHEC's reasonable progress 

analyses in the draft SIP: 

76 Section 7.7 - Title: As mentioned previously, SEVIC believes that a more 

appropriate title for this section is: "Which Control Measures for Individual 

Sources Achieve Reasonable Progress". 

76, Step 3 VISTAS suggests that this is not the correct place for the assessment of CAIR. 

Although EGUs do require separate consideration due to the implications of 

CAIR, that issue should not addressed here. Rather, analysis of the potential for 

achieving reasonable progress from EGUs is simply a sub-set of the "four-factor" 

analysis of individual sources identified by those Steps currently identified as #1, 

#2 and #4. SEVIC therefore recommends that the step currently identified as #3 

be incorporated within the step currently identified as #5, i.e., "Evaluate the four 

factors". 

76, 3rd 7 Line 8: SEVIC does not believe inclusion of North Carolina's CSA is appropriate 

in "Step 3". The underlying issue from SCDHEC's perspective is the extent of 

SO2 emission reductions achieved by CAIR from EGUs in South Carolina, and 

whether additional incremental controls on any of those emission units could 

achieve reasonable progress at Cape Romaine. Therefore, we believe that any 

DHEC reliance on details of North Carolina's CSA should be contrained to use of 

control costs from that program as a benchmark for defining the upper limit on 

acceptable control costs for reasonable progress. 

Last sentence: As SEVIC has emphasized, the question is not whether additional 

EGU control is reasonable, but instead whether visibility improvement achieved 

by any additional EGU control is reasonable. "h determining reasonable 

progress," South Carolina is obligated by 8 169A(g)(l) to take into consideration 

the other four factors listed in that provision. EPA's final reasonable progress 

guidance acknowledges that States may also consider "other relevant factors" in 

that determination. Consequently, the fact that EGUs are already required by 

CAIR to make substantial SO2 reductions is not, standing alone, sufficient 

justification for requiring no additional controls on those units. (See next 

comment.) 

76, last 7 SCDHEC concludes "that at this time these existing regulatory programs 

constitute reasonable measures for South Carolina's EGUs during this first 

assessment period." While SEVIC hlly concurs with the State's ultimate 

Appendix J - 140
conclusion, we encourage DHEC to frame the analysis which supports that 

conclusion around the statutory factors. 

First, the State is not looking for "reasonable measures" but rather for "reasonable 

progress". At issue is whether reasonable progress can be achieved by any of the 

State's EGUs. For that reason, we fail to see how SO2 reductions achieved by 

North Carolina's CSA from North Carolina's EGUs have any direct relevance to 

that issue. Rather, the projected control costs from North Carolina's CSA helped 

South Carolina to define what constitutes acceptable control costs for reasonable 

progress during the first planning period. 

SEVIC encourages DHEC (1) to incorporate its reasonable progress analysis for 

EGUs in the step entitled "Evaluate the four factors", and (2) to structure that 

analysis around consideration of the statutory factors. In particular, it appears that 

DHEC has found that the $/ton costs of any incremental SO2 controls on those 

units would not be cost-effective, and hence any visibility improvement achieved 

by such controls would not be reasonable. Moreover, that conclusion is bolstered 

by the facts that (1) existing CAA programs, in general, will achieve more 

visibility improvement at Cape Romain than could be achieved with the area's 

uniform rate of progress, and (2) a substantial portion of that expected visibility 

improvement at Cape Romain will be due to CAIR-required reductions from 

South Carolina's EGUs. 

77, 3rd 7 The various reasons which DHEC gives for adopting one percent as the 

contribution threshold for triggering a "four-factor" analysis are not compelling. 

SEVIC believes that justification must be based upon appropriate considerations 

of visibility impairment at Cape Romain in 201 8 and the fraction of that 

impairment attributable to South Carolina SO2 sources. "Trigger levels" for 

applying other programs such as CAIR, NOx SIP Call and NAAQS have no 

bearing on what would be an appropriate contribution threshold for the subject 

reasonable progress assessment. 

77-78 Step 5: Evaluate the four factors: The discussion under "Step 5" needs to be 

combined with the discussion under Section 8.1 -- "Four Factor Analyses for 

Sources affecting Cape Romain". Indeed, much of the discussion in Step 5 is 

repeated in Section 8.1. 

Curiously, DHEC's discussion here addresses only control cost. No mention is 

made of visibility improvement, compliance time, energy and nonair quality 

environmental impacts, or remaining useful life -- the other factors for 

"determining reasonable progress." As SEVIC has commented previously, 

DHEC's abbreviated discussion illustrates a fundamental deficiency in the content 

of this SIP. While the State clearly has the discretion to give overwhelming 

weight to its consideration of "costs of compliance," DHEC's SIP should, at a 

minimum, recognize the overall scope of the reasonable progress analysis by 

identifying those other factors and explaining how each is typically evaluated. 

Appendix J - 141
Even DHEC's discussion of the "cost of controls" has been abbreviated. While 

SEVIC is almost certain that DHEC considered detailed control costs for the 

candidate sources, this paragraph suggests a focus solely on "capital cost" and the 

"cost of labor." This discussion simply is not representative of the level of detail 

examined by VISTAS and the individual States. 

We also question why DHEC's discussion focuses so much on the cost of labor. 

After all, this is but one of numerous construction costs and subsequent operating 

costs. Indeed, as SEVIC has previously demonstrated, the issue of skilled labor 

availability speaks more to consideration, for this SIP, of the time-necessary-forcompliance statutory factor, primarily for non-EGUs having to install controls. 

In short, SEVIC recommends wholesale changes to the contents of Step 5. We 

suggest that the appropriate discussion should focus on identifying the factors 

considered in a reasonable progress analysis (including, by definition, visibility 

improvement) and on some of the issues or criteria which are evaluated for each 

of those factors, again making clear that the objective of the analysis is to 

determine reasonable progress (rather than selecting a reasonable control 

measure). At this point, no findings and conclusions are required. 

94 Section 8.0 -- Reasonable Progress Goals: SEVIC suggests that the introductory 

discussion about the RPGs is premature. A more appropriate place would be after 

completion of the source-specific reasonable progress analyses. 

94,4& 7 1" line: Change the word "States" to the singular, i.e., "a State". 

31d line: The Clean Air Act, and not EPA, provided the "four factors." As the 

preamble to the 1999 Regional Haze Rule makes clear, the analytical requirement 

provided by EPA was the so-called "glidepath" methodology for establishing 

reasonable progress goals. 

95, 2nd 7 Last sentence: Please identify where it is documented "that these sources may 

contribute to visibility impairment on the 20 percent worst days." Are these 

sources the same as those identified as contributin 1% or more of Cape % Romain's visibility impairment? (See page 77, 2" 7 and page 95, last I.) 

95, 4th7 Last sentence: As discussed above for page 76, last 7, South Carolina's decision 

not to require control measures for any EGU subject to CAIR should be framed 

more in terms of the result of a "four-factor analysis" for such units (where it 

appears that "costs of compliance" received the bulk of DHEC's consideration in 

this SIP). 

95, 5" I SEVIC is uncertain about the purpose of this BART-related discussion. Does it 

imply that the majority of EGUs subject to CAIR do not make any significant 

contribution to visibility impairment in Cape Romain? Is DHEC attempting to 

Appendix J - 142
make the point that visibility improvement achieved by incremental control on 

one of those EGUs would be so small -- so insignificant -- that it could not 

possibly be regarded as reasonable progress? Again, DHEC's rationale must be 

structured in terms of the statutory factors which influenced the State's decision. 

Section 8.1.1.3: In this section DHEC summarizes the results of a four-factor 

analysis for each affected source. The detailed, supporting analyses are provided 

in Appendix N. Each of these reasonable progress analyses consists of little more 

than an assessment of the "costs-of-compliance" factor, with such costs only 

evaluated in terms of dollars per ton of SO2 removed. 

SEVIC strongly supports South Carolina's authority to exercise its considerable 

discretion when making reasonable progress determinations by according 

substantial weight to the cost-of-compliance factor in each of the State's 

assessments. Moreover, SEVIC fully agrees with DHEC's conclusions that 

reasonable progress would not be achieved by applying new SO2 control 

measures to any of the affected sources during this planning period. 

Having said that, however, SEVIC reiterates its concern that the State's initial SIP 

likely will serve as a model or template for future revisions of its regional haze 

SIP. Therefore, it is imperative that DHEC provide in that document more 

detailed explanations of the purpose, scope and content of the overall statutory 

framework for a reasonable progress analysis. 

For example, although DHEC did not explicitly examine the visibility 

improvement achievable by any candidate control measure, that factor was used 

to define the universe of sources subject to reasonable progress analyses. In other 

words, the potential visibility improvement from controlling specific sources was 

a key consideration in the State's reasonable progress analyses. 

Moreover, SEVIC believes that consideration of visibility improvement could 

have substantial impact upon future reasonable progress analyses. In this SIP 

DHEC was able to rely upon abbreviated "four-factor analyses" because of the 

major improvements in visibility which will occur at Cape Romain due to 

emissions reductions from other CAA programs. However, major visibility 

improvements by other CAA programs may not be the case for a future planning 

period. In that circumstance, DHEC will need some broader statutory basis for 

deciding what sources may need to install controls to achieve reasonable progress. 

SEVIC submits that such decisions cannot be appropriately made without 

knowledge of the specific visibility improvement associated with each candidate 

control measure. Consequently, the "cost-effectiveness" of a control measure in 

terms of $/ton says absolutely nothing about the measure's ability to improve 

visibility in a class I area. On the other hand, "cost-effectiveness" measured in 

terms of $/dv provides a suitable metric for comparing the performance of 

Appendix J - 143
individual control measures, thereby allowing the State to select effective 

"reasonable progress" controls with a least-cost approach. 

SDHEC's current SIP should at least identify and explain the broader details of 

the statutory framework for reasonable progress analysis in order that regulated 

entities have appropriate notice and some certainty as to how their respective 

control obligations to achieve reasonable progress will be evaluated in the future. 

Unfortunately, some sources apparently have already been advised that their $/ton 

control costs will likely be "reasonable" for the next SIP revision. That 

characterization simply is an inappropriate premise for future reasonable progress 

planning. 

107, 3rd 7 3rd line: SEVIC continues to maintain that section 169A requires the 

determination of reasonable progress, not "reasonable control measures." Unless 

DHEC states otherwise, SEVIC assumes that the State's use of that latter term is 

essentially shorthand for describing candidate control measures which can 

achieve reasonable progress. 

107, 5th 7 2nd line: Same as preceding comment. 

109, 3rd 7 Lines 5-7: SEVIC believes that it is more appropriate for progress in a class I 

area to be evaluated by the State in which the class I area is located. For a class I 

area outside Georgia and affected by emissions from Georgia, Georgia EPD's 

responsibility appears to be an assessment of whether its current implementation 

plan is sufficient to enable the State with that class I area to meet the area's 

"established reasonable progress goals." 40 CFR 5 5 1.308(g)((6). 

SECTION I1 

Paee Comment 

2, last 7 Last line: After the word "further", add the word "detail". 

10, 2nd 7 lSt line: After the words ". . . emitted directly to the air", replace the remainder of 

the sentence with the following: ". . . or be formed downwind when certain 

gaseous emissions serve as precursors to the formation of particles." 

4th line: After the word "reducing", add the words "those precursors of '. 

7th line: Replace the words "The most important sources" with "Sources with the 

greatest emissions". 

10, 3rd 7 6th line: After the word "areas" at the beginning of the line, replace the word "or" 

with the words "consisting of '. 

Appendix J - 144
12, last 7 

15, 2nd 7 

15, last 7 

16, 3rd 7 

16, 6th 7 

16, last 7 

3rd line: Replace the word "states" with "a State". 

4" line: Replace the words "provide for" with "i.e.,". 

1" line: Replace the word "SIPS" with "a SIP". 

1" line: Begin this sentence as "Initial RPGs have been established in the State's 

long-term . . ." 

7" line: Replace the words "have been" with "were placed". Replace the word 

"within" with "during". 

Last line: Begin the last sentence as follows: "In determining BART, States must 

consider the five (5) factors . . .". 

4th line: After the words ". . . this Class I Federal area", change the remainder of 

the sentence to read: " and determines the BART requirements and long-term 

strategy necessary to achieve those RPGs within the first regional haze planning 

period." 

7th line: Change the word "option" to "measure". Delete the sentence beginning 

with "Congress considered . . ." because it is not germane to the remainder of the 

paragraph. 

9th line: CAIR was promulgated in 2005. 

Last sentence: Delete the words "where visibility is an important value" because 

they are unnecessary. 

3rd lie: Delete the words "and situation". 

5th line: Replace the words "compliance with existing control programs" with 

"emissions reduction requirements of other CAA programs." 

1 " line: After the words "by the RHR is the", add the word "deciview". 

Last sentence: Delete the word "conditions". 

Last line: Replace the words "governed by" with the word "among". 

1" line: Delete the beginning words "It is" and start the sentence with "The". 

Replace the words "that can be thought of as" with the word "define". 

2nd line: Replace the words "comparison of initial" with "difference between". 

3rd line: Replace the word "to" with the word "and". 

Appendix J - 145
Replace the word "indicates" with the word "is" 

Table 2.3-1: Inclusion of the visibility conditions in terms of Bext (Mm-I) makes 

the information in the table confusing. Because those values are not subsequently 

used in the State's determinations, SEVIC recommends deleting them from the 

table. 

19, last 7 lSt line: Replace the words "is the most important contributor to" with the words 

"contributes the most". 

4th line: After the words "sulfate levels", add "during the 20% worst days". 

20, lSt 7 1" line: Replace the words "most important" with the word "highest" 

21, lSt7 14th line: After the words "source of', add the word "fossil". 

21, 2nd7 7th line: Replace the word "important" with the word "significant". 

21, 3rd 7 2nd line: Change the word "contributor" to "contribution" 

4th line: The term "prescribed, wildland, wild fires" is confusing. SEVIC 

requests that this section provide a discussion of the different types of fires and 

why they are distinguished. 

2 1, last 7 2nd line: Change the words "most important" to " highest". 

5th line: Correct the spelling of "IMPROVE" 

22, lSt7 1 " line: Change the word "has" to "makes" 

24, lst 7 6th line: Delete the word "graphical". 

24, last 7 This discussion should identify the numerical values which the State subsequently 

used for baseline (25.5 dv) and natural background (12.2 dv). SEVIC 

recommends that it also specify the visibility improvement which would be 

achieved by 20 18 at the area's uniform rate of progress (3.3 dv). 

26, 2nd 7 4'h line: The term "facility" has a dual meaning. In this context, does "facility" 

mean at the plant level or at the unit level? 

26, 3rd 7 2nd & 3rd lines: SEVIC recommends that the third sentence be re-stated as: "This 

inventory is the annual emissions for the year that corresponds to the 

meteorological data. For this modeling effort, the base year was 2002." 

Appendix J - 146
26, last 7 

27, last 7 

3 1, last 7 

32, lSt7 

32, 3rd 7 

37, 5th 7 

50, title 

Last sentence: SEVIC questions why reference is made to use of the RRFs "in 

the attainment demonstration test." The use of such RRFs in this particular SIP 

should be identified. 

After the words ". . . are emissions fiom", add the word "larger". 

Last sentence: Why does this discussion focus on "large sources of IVOx"? 

First sentence: Again, why is this discussion specific to NOx emissions? SEVIC 

also questions how variations in EGU emissions can be attributed to "variability 

in meteorology". 

4th line: SEVIC suggests re-stating the sentence beginning with "IPM is a" as" 

"IPM is a dynamic linear optimization model that can be used to examine air 

pollution control policies for various pollutants from the entire electric power 

system throughout the contiguous U.S." 

For consistency, use past tense in all of the sentences. 

2nd line: Several references are made in this document to data in EPAYs CAIR 

analyses. SEVIC believes that such discussions should be more specific about the 

particular data referenced, including a citation to the Federal Register where that 

data is contained. Is this "general approach for assembling future year data" 

discussed in more detail in an appendix? 

1" line: After the words "sources whose", add the word "individual" 

In each discussion, DHEC states that the subject model "takes into consideration 

rules that are in effect that could impact the emissions . . ." Does this mean any 

and all applicable rules which will be in effect and implemented bv 20 18? 

1" line: SEVIC suggests that much more specifity is needed in place of the words 

"an important science update". 

3'd and 5th lines: After the words ". . . 96 percent of the" and "91 percent of the" 

add "2002". 

3'd line: The third sentence repeats the second one. 

4th line: What is "this demonstration"? 

Last line: After the words " . . . each Class I", the word should be "area". 

For any given planning period of a regional haze SIP, section 169A of the Act 

contemplates only a single long-term strategy. 

Appendix J - 147
53, 3rd 7 

53, 4th 7 

53, last 'I[ 

54, 3rd 7 

54, 4th 'I[ 

54, last 'I[ 

Replace the word "controls" with the words "reductions from other CAA 

programs". 

After the words "visibility benefits be realized", add the words "at Cape Romain". 

After the words "do we find the emissions", add the words "of those pollutants". 

At the end of this sentence add "at Cape Romain". 

Replace the word "represent" with the word "achieve". 

lSt sentence: SEVIC suggests re-stating this as" "Significant CAA emission 

control programs are being implemented, or will be implemented, between the 

baseline period and 20 18." 

Place the sentence beginning "Appendix M illustrates . . ." before the sentence 

which begins "The Clean Air Mercury Rule . . .". 

1 " bullet: There is no reason for mentioning the $1.2 billion. 

2nd bullet: There is no reason for mentioning that Crist is a significant source of 

NOx emissions in the Pensacola area. 

3rd bullet: There is no reason for mentioning the $654 million. 

Delete "RICE MACT standards" from the title. 

Add "RICE MACT" to the title. 

1'' sentence: Delete the words "outlined in the RHR. 

The discussion of EACs in the State should be updated. 

1" line: Replace the words "accounting for specific" with "considering". 

3rd line: Delete the words "the air quality benefits of' 

Because this repeats the last sentence of the preceding paragraph, delete this 

paragraph. 

lS' line: Correct the spelling of "VISTAS". 

4& line. The end of the affected sentence should read: ". . . as a result of the 

emission reductions required by existing federal and state regulations." 

Appendix J - 148
7th line: Delete the words "visibility is better than no change, or" and add the 

words "in visibility" after the words "10 percent improvement". 

There is no need for the first sentence. 

At the end of this paragraph, SEVIC suggests adding the following: "In short, in 

this initial LTS for Cape Romain, the amount of visibility improvement projected 

by 20 18 is independent of any contribution to visibility improvement by 

international emissions." 

66, 1' 7 Last sentence: There is no reason for including this sentence in this section of this 

document. 

66, 2nd 7 lSt line: Add the word "to" after the words "large contributor" 

2nd line: After the words "20 percent worst days", add the words "in Cape 

Romain". 

66, last 7 2nd line" Replace the words "each Class I Federal area" with "Cape Romain" 

67, 1'' 7 2nd line: Restate the sentence beginning with "To select the specific point 

sources" as follows: "To identify the specific point sources of SO2 that are likely 

to be major contributors to visibility impairment at Cape Romain, . . .". 

72, 2nd 7 lSt line: After the words "next step in the analysis", replace the word "is" with 

"was". 

72, 3rd 7 4th line: Replace the word "each" with the words "Cape Remain's". 

73 Figure 7.5.5-1: The title of the figure has a typographical mistake. 

75, lSt7 lSt line: After the words ". . . have already occurred," add the words "or will 

occur by 201 8, . . ". 

3rd line: Delete the word "existing". After the words "emission reductions", add 

the words "from other CAA programs." 

2nd line: Replace the words "feasibly be available" with "technically feasible" 

Replace the word "assign" with "estimate". 

3rd line: Replace the word "to" with "of'. 

3rd line: Replace the words "assigned to" with "considered for". 

1" line: "AOIs" should be singular, i.e., "AOI" 

Appendix J - 149
82, last 7 

lSt line: The State calculated the "fractional contribution" of what? 

5' line: The sentence beginning with "As discussed in detail in Appendix H.5" 

should be re-written as follows: "As discussed in detail in Appendix H.5, 

VISTAS modeling demonstrates that neither VOCs nor NH3 from point sources 

in the Southeast can reasonably be anticipated to contribute to visibility 

impairment in any Class I Federal area." 

4th line: The words "cause or" are unnecessary. 

2nd line: Change the word "improved" to "will improve" 

3rd line: "Change the words "affected by" to "which participate in the federal 

CAIR program." 

4' line: Delete the words "under part 96 AAA-EEE" 

5' line: Delete the words ", operate, or maintain". 

4' line: SEVIC believes that explanation of the removal capability of the FGD 

system is confusing. Does DHEC means "sulfuric acid" when it uses the term 

"sulfates"? Are there significant amounts of other "sulfates" in the combustion 

gases which the scrubber directly removes? 

6th line: Instead of "annual" costs, does DHEC mean "annualized cost"? 

3rd and 4th lines: This is another example of the confusing statement about FGD 

units removing "sulfates". 

8' line: Instead of "annual" costs, does DHEC mean "annualized cost"? 

7th and 8th lines: SEVIC believes the units of "pg/m3" were meant to be "dv". 

"Last sentence: The status of being "exempt from BART" means that it is "not 

subject to further BART analysis." SEVIC recommends deletion of that latter 

portion of the sentence. 

6th line: Change the words "should be exempted" to "is exempt". 

Last line: SEVIC suggests ending the sentence after ". . . the source is not subject 

to BART". 

3rd line: As previously discussed, this is not an accurate description of VISTAS' 

and SCDHEC's determination. 

Appendix J - 150
89, Last 1 2"d line: Change the words "were given exemption status" to "were found to be 

exempt fiom BART". 

90-93 Section 7.9: As SCDHEC acknowledges, the expected visibility improvement 

expected in 201 8 at Cape Romain due to emission reductions fiom other CAA 

programs was discussed previously. Therefore, SEVIC sees no reason for the 

redundant discussion of this section. The pictures on page 93 should be re-located 

to complement Figure 7.2.4-1. Instead of identifying the levels of visibility in those 

pictures in units of ~m-', the visibilities should be shown in units of deciviews. 

98-99 Section 8.1.1.1 : Inasmuch as the reasonable progress analyses of this particular 

SIP are solely related to SO2 emissions, SEVIC questions why DHEC has 

included discussions of (1) fabric filters, (2) ESPs and (3) COHPACTM. 

109 Section 1 1 .O, Title: Should be "COMPREHENSIVE. 

110, 1" 1 This sentence repeats the last sentence in the 3rd 1 of the previous page. 

Appendix J - 151
December 18, 2007 

Mr. John R. Cline 

Southeast Visibility Industry Coalition (SEVIC) 

c/o Troutman Sanders LLP 

Post Office Box 1122 

Richmond, VA 23218-1122 

Re: Regional Haze SIP Comments 

Dear Mr. Cline: 

As you know, the 1999 Regional Haze Rule (RHR) requires States to develop State 

Implementation Plans (SIPs) to reduce visibility impairment with the express intent that by 2064, 

the visibility in all Class I areas will be returned to natural conditions. 

South Carolina has prepared a draft SIP to address visibility and regional haze issues for our 

Class I Federal area, the Cape Romain Wilderness area. The Department submitted a notice to 

the South Carolina State Register in October 2007, soliciting comments on the draft SIP. 

On December 3, 2007, the Department received comments from the Southeast Visibility 

Coalition (SEVIC) on the State’s per-hearing draft SIP. These comments were summarized in 

two sections. Section I comments are dedicated to the State’s treatment of a variety of 

substantive issues including the interpretation of statutory requirements, specific inputs and 

assumptions for analysis, and the framework for determination of BART or reasonable progress. 

Section II addresses particular areas/specific statements in the SIP that SEVIC believes should be 

revised to more accurately describe the particular subject matter. 

The Department appreciates the depth and specificity of SEVIC in its review of the State’s SIP. 

The attached document serves to specifically address the comments received from SEVIC. 

During the process of developing its SIP, the Department was also required to consult with the 

US EPA Region 4 office as well as the appropriate Federal Land Managers. Each provided its 

own set of comments. 

The Department has reviewed the comments submitted by SEVIC and, where essential to 

address visibility impairment, has revised its SIP accordingly. The final SIP package is due to 

EPA by December 17, 2007. The Department hopes that the changes made to the final SIP 

package serve to address all the comments/concerns that were submitted during the public 

comment period. The Department remains committed to improving air quality in the region and 

appreciates the opportunity to work with SEVIC to produce the best possible SIP. 

Appendix J - 152
Should you have any further questions concerning South Carolina's regional haze SIP 

development, please feel fiee to contact me at (803) 898-2230 or masonrnr@,dhec.sc.aov. 

Sincerely, 

Robert J .' Brown, Yr., Director 

Division of Air Planning, Development & Outreach 

Bureau of Ail- Quality 

South Caroliria Department of Health and Environmental Control 

cc: Renee Shealy, Assistant Bureau Chief, SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

I'at Brewer, VISTAS Technical Advisor 

Appendix J - 153
Attachment A

Section I

Relative Contribution Assessment/Areas of Influence: 

The Department chose to adopt the bulk of the suggested changes put forth by SEVIC. The 

primary difference of opinion rests with the Department’s technical SO2 AOI analysis and the 

four factor analysis used to determine the State’s reasonable progress goals. Within comment 64 

on page 3, SEVIC calls into question the Department’s use of projected 2009 emissions data 

sensitivity runs used to establish relative contributions rather than projected 2018 emissions data. 

In conjunction with VISTAS, the Department used the emission sensitivities to determine which 

pollutants were most important to examine (not to assign relative contribution among states). 

Results from 2009 were similar to those based on earlier preliminary 2018 inventories. VISTAS 

states together determined that spending further time and money to repeat the analysis with 2018 

data and annual modeling rather than episodes would not generally change the conclusion that 

further reducing SO2 emission would result in a larger benefit than reducing NOX and VOC 

emissions. 

SEVIC is also concerned that the Department chose to focus its AOI analysis using 2000-2004 

data. In response to this concern, the Department would like to point out that the worst days 

were selected based on sulfate loading. As a result, there is no way to back out the influence of 

emissions in 2000-2004 and select different days to create a residence time for future emissions. 

To clarify, the Department’s intent was to establish which sources within the larger universe of 

sources identified as contributing to visibility impairment in 2002 remain important in 2018. 

The Department’s objective was/is not to re-draw the AOI for 2018, rather to determine which 

sources from 2002 remain important to visibility impairment. 

The Department also acknowledges the comments from SEVIC related to reducing primary 

carbon from point sources influenced by organic carbon or fires. The Department recognized 

that fires may play a greater role (particularly on the 20 percent worst days) at Cape Romain. 

However, current limited data prohibit the Department from further analyzing this issue. The 

Department, as well as VISTAS, recognizes that this area in particular will need to be more 

closely examined in future planning. 

Reasonable Progress: 

In consulting with several states and Federal Land Managers, the VISTAS states agreed to 

organize their respective SIPs in much the same fashion to facilitate a timely and complete 

review. As such, while the Department respects SEVIC’s opinion related to reorganizing 

Chapters 7 and 8, the Department has chosen to leave this discussion as is in order to facilitate 

consistency. 

SEVIC noted in its cover letter to the comments received on December 3, 2007, that the 

comments are based upon a pre-hearing draft version of the State’s SIP dated August 10, 2007. 

The Department believes that several of the comments related to SEVIC’s opinion that the SIP 

narrative was ‘insufficient’ and/or ‘deficient’ in describing the statutory factors have been 

addressed. Specifically, Chapter 8 of the narrative has been updated to include information 

3 

Appendix J - 154
4 

received by the Department in November 2007. This information enhances the Department’s 

discussion and application of the statutory factors, which results in a much more in-depth 

discussion of the State’s approach to establishing reasonable progress goals. 

 

Section II

Given these suggested changes were primarily related to verbiage and/or word choice, the 

Department chose to adopt most of the suggested changes put forth by SEVIC. 

Appendix J - 155
%. 

SaTH 

GZROLINA 

v 

CHAMBER 

COMMERCE December 1 1.2007 BUREAU OF All1 UUALI 1-Y 

Ms. Maeve S. R. Mason 

Regulatory Development Section 

SCDHEC 

Bureau of Air Quality 

2600 Bull Street 

Columbia. SC 2930: 

Re: South Carolina State Implementation Plan Revisions 

Section 169A of the Clean Air Act ("Regional Haze Rule") 

Dear Ms. Mason: 

The following comments are provided on behalf of the South Carolina Chamber 

of Commerce ("Chamber") regarding the proposed changes to SC State 

Implementation Plan (SIP) to address Section 169A of the Clean Air Act 

("Regional Haze Rule"). 

The Chamber, with over 2000 members, represents a very diverse group of 

businesses with interests in South Carolina. These comments do not preclude 

member companies from submitting additional comments, either individually or 

through other trade associations and coalitions. In particular, many Chamber 

member companies are part of the Southeast Visibility Industry Coalition 

("SEVIC"). The comments submitted by SEVIC have been reviewed and are 

generally supported by the Chamber, and as such, are included by reference. 

Chamber members support the improvement of air quality in South Carolina, 

including improvements in regional haze. Our members are equally concerned 

that the methodologies, models and data used in establishing goals are reasonable, 

attainable and cost effective. The Chamber's concerns and comments are 

provided in the spirit of achieving the goals of the Regional Haze Rule without 

unnecessary impact on business and industry in South Carolina. 

1201 Main Street 

Suite 1700 

Columbia 

South Carolina 

29201 -3229 

Fax 

8031779-6043 

Appendix J - 156
Ms. Maeve S R Mason 

December 1 1.2007 

Page 2 

The Chamber is concerned about the time allowed for review and comment of the 

SIP. 

The proposed SIP consists of approximately 5000 pages (e.g. SIP and 39 appendices) of 

highly complex technical theory expressed in mathematical relationships (models). This 

material was provided for review on SC DHEC's website beginning on November 15, 

2007. The material, much of it developed andlor revised within the last few months, 

forms the basis for regulatory decisions which may potentially require hundreds of 

millions of dollars in expense over the next six decades in order to achieve the stated goal 

of the Regional Haze Rule (e.g., returning visibility at the Cape Romain Class I area to 

that which existed prior to man's presence). 

The Chamber has serious concerns that in preparing the proposed SIP revisions, SC 

DHEC has relied almost entirely on new and inadequately tested visibilitji 

methodologies, models and data developed by the Visibility Improvement State and 

Tribal Association of the Southeast (VISTAS) and the Interagency Monitoring of 

Protective Visual Environments (IMPROVE) organizations. The methodologies, models 

and data are used to establish theoretical cause-and-effect-relationships between 1) 

current visibility, 2) man-made emissions, 3) naturally-occurring emissions, and 4) 

"naturally occurring" visibility conditions. 

To our knowledge, there has been some scientific peer review of certain aspects of these 

procedures, but in many cases the testing has not focused upon visibility characterization. 

For example, CALPLW has been peer reviewed for predictions of concentrations of 

criteria pollutants, but not for chemical transformation and visibility calculations. The 

IMPROVE equation has been tested with current atmospheric pollutant loadings, but not 

for projecting future cases with much different characteristics. In short, there are no 

experimental databases available to test the consequences of what the Regional Haze 

Rule is mandating - a massive reduction in the nation's pollutant emissions. As noted 

below, such testing will be possible only after the first milestone period in the Regional 

Haze Rule implementation is completed and should be done before any further RHR 

milestones are attempted. 

This evaluation has not been possible to date because of the lack of massive emission 

reductions within a short period. The emission reductions that will occur as a result of 

CAR, CAMR, NOx SIP call, etc. present a unique and essential opportunity for a 

complete model evaluation process relative to the Regional Haze Rule goals. The testing 

results should be submitted to the public for review and comment before a conclusion of 

adequate model performance is possible. Likewise, the regulated community should not 

be presented additional information requests under the Regional Haze Rule until this 

model performance evaluation is complete. 

The Chamber supports SC DHEC's approach and conclusions regarding Best 

Available Retrofit Technology (BART). 

The Chamber appreciates the thousands of hours expended by SC DHEC's' management 

and staff on the Regional Haze SIP. We understand that SC DHEC has been an active 

Appendix J - 157
Ms. Maeve S R Mason 

December 1 1,2007 

Page 3 

member of VISTAS, along with other southeastern states, EPA Region 4 and the Federal 

Land Managers. We understand that SC DHEC is encouraged to consult with these 

organizations in making decisions relative to their SIP, but is not required to utilize their 

input, especially where it is found to be inaccurate or deficient in some manner. 

The Chamber supports the decisions that SC DHEC has made with regard to the unique 

local conditions that exist in coastal environments. Where it has been necessary to depart 

form VISTASIIMPROVE guidance for reasons of accuracy andor questionable data 

quality, SC DHEC has appropriately done so. The errors and omissions, especially 

regarding the data quality and visibility impacts of naturally-occurring sea salt, would 

have gone uncorrected had SC DHEC not stepped forward and applied its own stringent 

quality guidelines and made necessary corrections. As a result, the Chamber 

complin~ents and supports SC DHEC on its analysis and decisions related to the BART 

portions of the Regional Haze Rule. 

The Chamber asks that clarification be provided on the emissions data used in 

various sections of the SIP (e.g. BART eligibility, modeling, and deciview impacts). 

It should be noted that Appendix H.4 contains numbers used for BART applicability 

determinations and not the more accurate actual emission rates used for modeling 

purposes. Also, there appears to be inconsistencies in the reported deciview impacts 

listed on pages 82 and 89 of the draft SIP. 

The Chamber is concerned about the uncertainties in the uniform rate of progress 

determinations. 

Based on a preliminary review limited by the time available in this review period, the 

Chamber has identified the following areas of uncertainty in the methodologies, models 

and data and requests that EPA formally address and resolve each before any uniform 

rate of progress (e.g., glidepath) is accepted for regulatory purposes. This review will be 

especially important to be completed and corrective actions taken before any future 

Regional Haze Rule-related emissions reductions are considered. 

"Common Sense" Coastal Knowledge Appears to be Missing from the 

Equations -Weather (in the form of natural obscuration) is clearly the 

predominant factor affecting visibility at Cape Romain, yet it is not addressed 

anywhere in the SIP or supporting documents. The marine environment is vastly 

different from the western mountains and upland plains where many of the 

IMPROVE measurements were taken and used by the organization that developed 

the visibility models. The majority of the Cape Romain National Wildlife Refuge 

consists of water, which represents an enormous heat source in the colder months 

and heat sink in the warm months. During both seasons, the large mass of water 

has a considerable affect on local weather patterns and visibility through naturally 

occurring fog, local showers and thunderstorms, morning inversions (especially 

during the colder months), and diurnal coastal wind patterns. These conditions 

Appendix J - 158
Ms. Maeve S R Mason 

December 1 1,2007 

Page 4 

either do not exist or are significantly different from conditions in the arid and 

semi-arid western U.S. Weather impacts are not considered in 1) the models or 2) 

as natural causes of visibility impairment (e.g., the 20% worst visibility days). 

Not considering the single most significant cause of visibility impairment 

(especially for the 20% worst visibility days) skews the data, the determination of 

"natural background visibility," and the determination of Uniform Rate of 

Progress. 

Hurricanes, Storms at Sea, and Breakers along the Coast Suspend Sea Salt in 

the Atmosphere- Second to weather, suspended sea salt is known to be a 

significant contributor to natural visibility impairment in coastal and near-coastal 

areas. However, it does not appear sea salt was considered in determining either 

the natural background conditions or Uniform Rate of Progress (glidepath) for 

Cape Romain. Page 22 contains the statement "As Figure 2.4-2 indicates, NaCl 

contributions to visibility impairment are most important on the 20 percent 

clearest days when sulfate and POM levels are low. NaCl levels do not contribute 

significantly to visibility on the 20 percent worst visibility days." These 

statements are counter-intuitive and indicate the methodologies, models and data 

developed may be completely missing the mark as far as reflecting the actual 

conditions that occur (and historically occurred) in coastal Class I areas such as 

Cape Romain. (Figure 2.4-3 on the page 23 appears to acknowledge the impact of 

sea salt on the 20% worst visibility days and contradict the conclusion at the 

bottom of page 22.) 

3. Sea Salt Data Collection - The analytical methods used at IMPROVE 

monitoring sites have been inappropriate for accurately measuring sodium and 

chloride that is essential for accurate determinations of Sea Salt concentrations. 

The result has been a database of very poor (e.g., unusable) quality when 

compared to EPA's own data quality guidance. The best analytical method for 

determining sea salt is reported by analytical experts to be Neutron Activation. 

Although this technique is proven, available and affordable, it has not been 

utilized. The Chamber recommends sea salt measurements using Neutron 

Activation should begin immediately. Additionally, we recommend that EPA 

should immediately discontinue requiring that states use existing poor quality 

data as input to the New IMPROVE model. Doing so is a direct violation of the 

Agency's data quality guidelines. The age-old adage that the "results of the 

model are only as good as the quality of the input" certainly applies in this case. 

4. Glidepath Correction to Reflect Accurate Sea Salt Measurements - Once 

accurate sea salt concentrations are determined using the appropriate techniques, 

these should be used as input to the models. Additionally, the Uniform Rate of 

Progress (e.g., glidepath) should be adjusted to properly reflect the impact of sea 

salt on naturally-occurring visibility. Doing so has the potential to alter the end 

point of the glidepath considerably, and will more accurately reflect natural 

conditions in this coastal environment. For example, earlier work performed by 

VISTAS using a very realistic sea salt concentration of 1.30 uglm3 (sodium 

method) for Cape Romain resulted in a natural background condition of 14.1 

Appendix J - 159
Ms. Maeve S R Mason 

December 1 1,2007 

Page 5 

deciview instead of the 12.1 deciview currently reported in the draft SIP for the 

average 20% worst days. The 12.1 deciview is based on a sea salt concentration 

of 0.2 ugJm3, which is significantly lower than coastal area sea salt 

concentrations reported in the scientific literature. 

5. Planned Emission Reductions - Since visibility is dependent to some extent on 

emissions of S02, NOx and fine particulates, the SIP should provide a table and 

bar chart clearly and simply showing chronological reductions expected as a 

result of the Clean Air Interstate Rule, the Clean Air Mercury Rule, the NOx SIP 

Call and other regulations and planned emission reductions between now and 

2064. These reductions can then be compared to visibility improvement predicted 

by the models. 

6. Visibility Improvement Does Not Calibrate to Emission Reductions - After 

plots of the emission reductions (see #5 above) are made available, the visibility 

model should be calibrated to determine if it is accurately reflecting the visibility 

improvement resulting from planned emission reductions. The Chamber 

understands that emissions will decrease by 73% by 2018, but the model only 

predicts a 26% reduction in haze. The model appears to be inaccurate to the point 

that one could easily conclude the 2064 goal can never be achieved. The 

Chamber is concerned that successive rounds of costly emission reductions may 

be mandated for South Carolina businesses in attempts to achieve an erroneously 

calculated and unattainable goal. 

The Chamber recommends that before any future emission reductions are 

mandated in the implementation of the Regional Haze Rule, the effects of the first 

round of reductions should first be evaluated with the modeling tools to assure 

that the observed visibility improvements are accurately depicted by the models. 

Since the emission reductions will not be completely in effect until perhaps 2014 

and it will take perhaps 3-4 years to get reliable measurements of the benefits, we 

believe that the initial assessment of the modeling tools and corrections will not 

be completed until 2020. At that time, if we have modeling tools that adequately 

replicate the expected improvements in visibility, then they may be used for 

future assessments of emission reductions required to stay on the glidepath. 

Otherwise, the modeling tools will need to be adjusted to achieve adequate 

performance, and only after that will future emission reduction assessments be 

feasible. 

7. Naturally-Occurring Ammonia and Sulfates are Not Considered - In Section 

2.4 (page 20), ammonium sulfate is identified as the largest contributor to haze at 

Cape Romain. All ammonium sulfate is apparently assumed to be the result of 

man-made emissions. The Chamber questions why the contribution of natural 

biogenic sources of ammonia and sulfates are not considered when determining 

naturally-occurring background visibility. Natural decay of the abundant 

vegetation in Cape Romain's saltwater marshes releases significant quantities of 

ammonia as a result of the reducing environment and the anaerobic 

biodegradation that takes place in the soils and marine sediments. Likewise, 

Appendix J - 160
Ms. Maeve S R Mason 

December 1 1,2007 

Page 6 

sulfates are released in large quantities from both sea water (where sulfate ions 

comprise 7.7 wt% of the total salts present in all seawater) and from 

phytoplankton that release large amounts of sulfates to the atmosphere. Again, by 

not recognizing these natural sources of haze when establishing the Uniform Rate 

of Progress end point, severe financial burden will likely be placed on business 

and industry in future attempts to achieve unrealistically low visibility goals. 

8. Back Trajectories Are Not Appropriate for Conducting Area of Influence 

Analysis - The back trajectory modeling approach used to determine an Area of 

Influence is not appropriate and should not be used. Other approved modeling 

techniques would provide much more detailed information, and better represent 

the dispersion of industrial and other plumes. It is commonly known that grid 

based modeling techniques such as CMAQ, which uses large grid sizes and many 

subjective assumptions, do a poor job of evaluating point source plumes. The 

Chamber's concern about using back trajectories have been discussed in other 

scientific venues which document the technical shortcomings of using back 

trajectories over long distances and over extended periods of time. 

9. Cause-Effect Relationship between Ammonium Sulfate and Visibility Has 

Not Been Clearly Established - The fact that high sulfates (and other speciated 

salts) were measured on the particulate filters at Cape Romain during the 20% 

worst visibility days (page 20) does not confirm a cause-effect relationship as 

suggested. It is highly likely that the same naturally-occurring conditions that 

cause the visibility impairment, such as an inversion for instance, would trap and 

concentrate naturally-occurring sulfates and ammonia released from plankton and 

marine marsh sediments. Suggesting conclusively that the elevated 

concentrations of ammonium sulfate are 1) all from man-made emission sources, 

and 2) are the cause of the visibility reduction rather than the result of naturallyoccumng atmospheric conditions are unsupported. EPA must prove the science 

behind this and the many other theories used in the methodologies, models and 

data before they are suitable for use for regulatory purposes such as 

implementation of EPA's Regional Haze Rule. 

10. The Sources of Organic Carbon and their Impact on Visibility Appear to be 

Incomplete - Section 2.4 (page 22) states that Particulate Organic Matter (POM) 

is the second most important contributor to regional haze at Cape Romain. The 

source of this haze, naturally occumng or man-made, is not clearly explained. It 

is common local knowledge that the indigenous local pine forests and both the 

natural and prescribed burning of nearby marsh grasses for enhanced wildlife 

management, results in significant emissions of organic carbon. Long-leaf 

(loblolly) pine forests predominate in the upland reaches of Cape Romain, and 

this species requires fire to sustain its life-cycle. If one assumes that lightninginduced natural fires occurred prior to man's existence, most of the POM 

measured today should also be considered naturally-occurring. We understand 

that Carbon-14 studies at Class I areas in the Southeast support this and have 

generally found that about 80 to 90% of the carbon is of modern origin (i.e., non 

fossil, hence not from petroleum and coal). Attributing organic carbon to manAppendix J - 161
Ms. Maeve S R Mason 

December 1 1,2007 

Page 7 

made emissions and not reflecting this in the Uniform Further Progress 

(glidepath) calculations is inaccurate and misleading and must be corrected. 

The Chamber recommendation is that the visibility associated with natural 

conditions needs to be totally re-evaluated to account for natural and non-USA 

sources of the particulates that cause visibility impairment before any future 

emission reductions are considered under the Regional Haze Rule. The findings 

of what constitute natural conditions should be submitted to the public before 

review and comment before they are considered final. 

11. Reliability of Data Collected at Cape Romain - The Chamber has considerable 

concerns about the quality of air quality data collected at the IMPROVE site 

located at Cape Romain. This data is used as the basis for virtually all of the 

regulatory conclusions regarding current and natural conditions. This monitoring 

site was subjected to a review of monitoring sites in 2007 by a stakeholder group 

which included members of the Chamber, DHEC and NGO's. The site has 

several identified deficiencies, including: 

a. The monitor is located only 47 feet from a dirt road leading to the NWR's 

maintenance complex. Particulate measurements used for RHR 

implementation need to be extremely accuratelprecise if they are to be 

used in determining "natural background conditions" and "glidepaths," yet 

measurements at this monitor are potentially skewed by emissions from 

the dirt roadway and other nearby sources. 

b. Likewise, organic carbon measurements are presented as a primary cause 

for regional haze, yet the Cape Rornain NWR maintenance shop building 

and yard are located only 330 feet from the monitor. Heavy diesel 

equipment are housed, fueled, operated and repaired at this location and 

must travel directly past the monitor when used within the NWR, 

potentially skewing organic carbon measurements. 

c. The Cape Romain monitor is located 0.2 miles from the Intracoastal 

Waterway. This section of the ICW receives very heavy local recreational 

boat traffic as we!l as considerable traffic from large yachts and 

commercial vessels being transported up and down the Atlantic coast. The 

close proximity to the monitor can bias the very precise measurement of 

particulates, organic carbon, sulfate and other parameters measured. 

d. A large stand of pine trees is located only 32 feet from the monitor, 

contributing organic carbon and particulates that would cause the data to 

be potentially unusable for regional haze calculations. 

e. The Chamber believes there are much better locations to monitor air 

quality within the Cape Romain NWF. The locations may not be as 

accessible and convenient, but the accuracy of the data must be the 

paramount consideration given the dollar magnitude of regulatory 

decisions that may result from the use of the collected data. 

Appendix J - 162
Ms. Maeve S R Mason 

December 1 1,2007 

Page 8 

Conclusions 

The Chamber complements SCDHEC on the extensive effort put forward to support 

VISTAS and the other stakeholder groups participating in the Regional Haze Rule 

implementation in South Carolina. The goal of the Regional Haze Rule is one that the 

Chamber and its members support. 

Creating a Regional Planning Organization such as VISTAS, however, does not relieve 

EPA or SCDHEC from their mandated responsibility to use sound, proven science and 

reliable data in malung regulatory decisions. Despite the existence of over 5000 pages of 

supporting documentation provided for review, we find the methodologies, models and 

data may have serious shortcomings and lack of appropriate evaluation. We do not feel 

this is the responsibility of the state agency, but rather the responsibility of EPA, the 

FLMs and the organizations created to assist in the implement the Regional Haze Rule 

(e.g., VISTAS, IMPROVE, etc.). 

Until an extensive level of review, verification and quality assurance is begun in about 10 

years (after implementation of CAIR and additional measurements), the Chamber 

contends that the methodologies, models and data are not suitably tested for future 

analysis of visibility impairment, and should not be used in future regulatory decisionmaking associated with the Regional Haze Rule. 

Thank you for the opportunity to comment and for your consideration of these comments. 

If you have any questions, please feel free to call me at 803-425-4625. 

Sincerely, 

Names P. Witkowski 

Air Subcommittee Chair 

SC Chamber of Commerce Environmental Technical Committee 

cc: Jack Preston - SCANA / ETC Chair 

Ben Twilley - SC Chamber of Commerce 

Roxie Williamson - SC Chamber of Commerce 

Appendix J - 163
BOARD: 

Paul C. Aughtry, 111 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

BOARD: 

Henry C. Scott 

Steven G. Kisner 

Secrerary C. Earl Hunter, Commissioner 

A.c-,motiwg ~rrld protecting the health of the public and the erzvi~onrnent 

M. David Mitchell, MD 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

December 2 1,2007 

James P. Witkowski 

Air Subcommittee Chair 

SC Chamber of Commerce Environmental Technical Committee 

120 1 Main Street Suite 1700 

Columbia, SC 29201-3229 

Re: Regional Haze State Implementation Plan (SIP) Comments 

Dear Mr. Witkowski: 

South Carolina has prepared a draft SIP to address visibility and regional haze issues for the 

State's Class I Federal area, the Cape Romain Wilderness area. The Department submitted a 

notice to the South Carolina State Register in October 2007, soliciting comments on the draft 

SIP. 

On December 12,2007, the Department received comments from the South Carolina Chamber of 

Commerce Environmental Technical Committee on the State's per-hearing draft State 

Implementation Plan (SIP). These comments were organized into several sections and called 

into question the State's treatment of a variety of substantive issues, including the interpretation 

of sea salt in the new IMPROVE equation, the State's approach and conclusion regarding Best 

Available Retrofit Technology (BART) and planned emission reductions, the uniform rate of 

progress, and the general reliability of data collected. 

The Department appreciates the depth and specificity of the Chamber's review of the State's SIP. 

The attached document serves to specifically address the concerns and comments presented by 

the Chamber. 

The Department has considered these comments as well as additional comments submitted by 

other interested parties. In reviewing these comments, the Department has evaluated the 

significance of each in terms of addressing visibility impairment and, where appropriate, has 

revised the SIP accordingly. 

The final SIP package was due to the Environmental Protection Agency (EPA) on December 17, 

2007. Due in part to the comments received by the Chamber, the Department has delayed its 

submittal of the State's SIP to the EPA to provide time for adequate comment response. 

However, the Department intends to submit its final SIP package to the EPA by December 21, 

2007. The Department hopes that the changes made to the final SIP package serve to address the 

comments/concerns that were submitted during the public comment period. The Department 

SOL'TH C:AROLINA DEPARTMENT OF HEALTH A N D E N V I R O N M E N T A L CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 164
Mr. Witkowski 

December 2 1,2007 

Page 2 

remains committed to improving visibility in the region and appreciates the opportunity to work 

with the Chamber to produce the best possible SIP. 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please feel free to contact Maeve Mason of my staff at (803) 898-2230 or 

masonrnr~,dl~ec.sc.gov. 

Robert $. Brown, ~r., Director 

Division of Air Planning, Development & Outreach 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Renee Shealy, Assistant Bureau Chief, SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Appendix J - 165
Responses to Comments from SC Chamber of Commerce 

Implementation of the Regional Haze Rule is planned over the sixty-four year period from 

2000 to 2064. Our understanding of emissions inventories and visibility will improve over 

this same period. This first regional haze state implementation plan follows the best 

guidance and science available in 2007. The science will continue to be reviewed and 

updated as better information is available and these improvements will be considered in the 

2012 interim review. 

SC has reviewed the Chamber’s concerns and offers the following technical responses. 

1) The Chamber is concerned about the time allowed for review and comment of the 

SIP and that the scientific basis is new and inadequately tested.

VISTAS has provided an open stakeholder process since 2002 and members of the SC 

Chamber of Commerce have participated in VISTAS. All of the methods and results have 

been provided for peer review by the scientific community and by VISTAS participants as 

they were developed. Open dialog has been encouraged and Chamber members have 

been invited to participate. 

The scientific basis of the South Carolina State Implementation Plan has been well 

documented. Several scientific journal articles have been published in peer review 

journals documenting monitoring data analyses, evaluation of natural visibility conditions, 

performance of emissions and air quality models, and air quality responses to emissions 

reductions. These published articles1

,

2

,

3

,

4

,

5

,

6

 were included in the SC SIP Appendices to

demonstrate the effort that has been made to assure scientifically defensible analyses are 

used in the State Implementation Plan. 

 

The IMPROVE monitoring network was established in 1985 to implement a long term 

monitoring program to establish the current visibility conditions, track changes in 

visibility, and determine causes of haze in national parks and wilderness areas. IMPROVE 

1

 Brewer, P. F., and Adhloch, J. 2005. Trends in Speciated Fine Particulate Matter and Visibility across 

Monitoring Networks in the Southeastern United States. J. Air & Waste Management Association 55:1663-1674 2

 Tombach, I. and Brewer, P. 2005. Natural Background Visibility and Regional Haze Goals in the 

Southeastern United States. J. Air & Waste Management Association 55:1600-1620. 3

 Morris, R. E., Koo, B, Guenther, A., Yarwood, G., McNally, D., Tesche, T.W., Tonnessen, G., Boylan, J. and 

Brewer, P. 2006. Model sensitivity evaluation for organic carbon using two multi-pollutant air quality models 

that simulate regional haze in the southeastern United States. Atmospheric Environment 40: 4960-4972. 4

 Morris, R. E., McNally, D. E., Tesche, T.W., Tonnessen, G., Boylan, J. W., and Brewer, P. 2005. Preliminary 

Evaluation of the Community Multiscale Air Quality Model for 2002 over the Southeastern United States. J. Air 

& Waste Management Association 55:1694-1708. 5

 Tesche, T.W., Morris, R. E., Kou, B. Guenther, A., McNally, D. E., Tonnessen, G., Boylan, J. W., and Brewer, 

P. 2006. Diagnostic Model Performance Evaluation Using Multiple Air Quality Models for Simulating Ozone, 

Particulate Matter and Regional Haze in the Southeastern U. S. Atmospheric Environment 40: 4906-4919. 6

 Odman, M. T., Hu, Y., Unal, A., Russell, A. G. and Boylan, J. W, 2007. Determining the sources of regional 

haze in the Southeastern U.S. using the CMAQ model. Journal of Applied Meteorology and Climatology, 46, 

11, pp. 1731-1743, 

Appendix J - 166
currently operates monitors at 110 sites representative of 156 Class I areas, with an 

additional 49 sites operated following IMPROVE protocol and funded by other federal, 

state, and tribal organizations. IMPROVE has rigorous monitoring standard operating 

procedures and data quality standards7

. The Chamber’s statement that SC has relied on 

new and inadequately tested methodologies is incorrect. 

2) The Chamber incorrectly states that there have been no previous massive reductions 

in pollutants emissions that could be used to evaluate air quality benefits. In fact, 

SO2 reductions under Title IV of the 1990 Clean Air Act Amendments have resulted in 

significant reductions in sulfate deposition8

 and aerosol loadings. Visibility 

improvements in response to SO2 emissions reductions have been documented by th

IMPROVE monitoring network

e 

 nitrate 

deposition and ozone. 

t naturally occurring sea salt at Cape Romain has not 

ither 

e comments then cite sections of the Narrative 

at discuss how sea salt was addressed. 

how 

n of both natural background and current conditions in the new 

PROVE equation12. 

f NaCl. 

 

9

,

10. As discussed in Appendix B, Conceptual 

Description, IMPROVE data demonstrates visibility improvement at 8 sites in the 

VISTAS region, including Cape Romain, over the period 1995 to 2004. In addition to 

SO2 emissions reductions, NOx emissions reductions under Title IV and under the NOx 

State Implementation Plan (SIP) Call have resulted in significant reductions in

8

3) The Chamber is concerned tha

been adequately considered. 

The Chamber’s statement on page 4 that sea salt was not considered in determining e

the natural background conditions or Uniform Rate of Progress (glidepath) for Cape 

Romain is incorrect and confusing since th

th

The EPA Guidance for Tracking Progress in under the Regional Haze Rule11 defines 

current and natural background visibility conditions should be calculated to derive a

uniform rate of progress toward natural background visibility in 2064. SC and the 

VISTAS states chose to use the new IMPROVE equation and the new calculation of 

natural conditions to define the uniform rate of progress for Cape Romain. Sea salt is 

included in the calculatio

IM

Sea salt is composed primarily of sodium chloride, NaCl. IMPROVE uses Cl-, measured 

by ion chromatography of samples collected on the Nylon filter, as an indicator o

Cl- may volatize off the filter and may under represent sea salt values. Routine 

7

 IMPROVE Standard Operating Procedures and IMPROVE Aerosol Quality Assurance Project Plan 

http://vista.cira.colostate.edu/improve/Publications/publications.htm 

8

 Dennis, R. Haeuber, R., Blett, T., Cosby, J., Driscoll, C., Sickles, J., Johston, J. 2007. Sulfur and Nitrogen 

Deposition on Ecosystems in the United States. Environmental Management, Dec 2007, pp. 12-17. 9

 Malm, W.C., B.A.Schichtel, R.B. Ames, and K.A. Gebhart, 2002. A 10-year spatial and temporal trend of 

sulfate across the United States, J. Geophysical Research, 107. 10Spatial and Seasonal Patterns and Temporal Variability of Haze and Its Constitutes in the United States. 2006. 

IMPROVE Report IV. Cooperative Institute for Research in the Atmosphere. 

11 EPA-454/B-03-004, September 2003 

12 Pitchford, M., Malm, W., Schichtel, B., Kumar, N, Lowenthal, D., Hand, J. 2006. Revised Algorithm for 

Estimating Light Extinction from IMPROVE Particle Speciation Data. J Air & Waste Management Assoc. 

Appendix J - 167
 3 

d 

al 

onsidered an upper bound for sea salt while Cl- measurement is probably a lower bound. 

4 

are 

e 

d 

n with 

, 

nd sea 

s 

isibility condition would be higher using Na+ than using Cl- in the IMPROVE equation. 

alt 

ple recalculation of natural background 

onditions using Na+ instead of Cl-. 

 

IMPROVE analysis uses X-ray Fluorescence (XRF) spectroscopy for samples collected 

on the Teflon filter for elements, including Na. IMPROVE does not consider elemental

Na to be a reliable indicator for sea salt. Ion chromatography provides a more reliable

measure of Na+ ion, but IMPROVE does not routinely fund ion chromatography for 

cations. This is an economic decision in balancing costs for the 159 monitors in the

network. VISTAS funded non-routine ion chromatography analysis of Na+ on the 

IMPROVE filter samples for Cape Romain and several other VISTAS sites for the perio

Oct 2002 through Dec 2004. These Na+ data, corrected to account for Na+ associated 

with soils, provide an alternative estimate of sea salt values over a range of meteorologic

and seasonal conditions that is higher than the sea salt estimate based on Cl-. Because 

some of the measured Na+ may actually be associated with NO3 rather than Cl, Na+ is 

c

Figure 1 on the next page of this response illustrates light extinction for the 2000-200

baseline period under the Regional Haze Rule, calculated using the new IMPROVE 

equation. Light extinction from sea salt is largest on the days when extinction from 

sulfate and organic carbon is lowest. This suggests that sea salt values are highest when

winds are from the ocean rather than the mainland. Many of the days are classified as 

20% best visibility days. On days that aerosol loading of sulfate and organic carbon 

highest, sea salt is a very minor component of light extinction. Beginning in 2004, 

VISTAS has funded operation of a nephelometer at Cape Romain. The nephelometer 

measures light scattering by aerosols and gases in the atmosphere at ambient temperatur

and relative humidity. This direct measure of visibility correlates well with calculate

light extinction based on measured aerosol loading at the Cape Romain. This direct 

measure can be compared to calculated visibility using the new IMPROVE equatio

either Cl- or Na+ as the measure of sea salt. Because fine particle mass and light 

extinction at Cape Romain under current conditions are dominated by ammonium sulfate 

and organic carbon and because sea salt is a very minor component of total aerosol mass

it is not possible to demonstrate that one indicator of sea salt is a better than another13. 

The new IMPROVE equation uses Cl- as a measure of sea salt. If Na+ were to be used 

instead of Cl- to calculate sea salt mass, current visibility would be little changed because 

current visibility on the days defined by IMPROVE as being the worst visibility impaired

due to aerosol loadings are dominated by ammonium sulfate and organic carbon a

salt has little additional contribution. However, for 20% best days under current 

conditions or estimated natural conditions in the absence of anthropogenic sources of 

carbon and sulfate, sea salt becomes a larger percentage of total mass and the difference

in the two estimates of sea salt becomes more important. Thus the natural background 

v

Because the 20% worst days would need to be selected based on the revised sea s

values, it is not possible to provide a sim

c

13 Tombach, I. 2007. Evaluation of Alternative Methods for Estimating Sea Salt Concentrations at Cape 

Romain. Report to VISTAS, Feb 18 2007. 

Appendix J - 168
ROMA1

Baseline Extinction, New IMPROVE Algorithm

Figure 1. Speciation of all data collected at the Cape Romain site for 2000 to 2004. The 

red line indicates the threshold above which days are counted as 20% worst days for each 

year. 

20% W > 92

0

50

100

150

200

250

300

J-02F-02

M-02

A-02

M-02

J-02J-02

A-02

S-02

O-02

N-02D-02

Extinction (Mm -1)

20% W > 102

0

50

100

150

200

250

300

J-01

F-01

M-01

A-01

M-01

J-01

J-01

A-01S-01O-01N-01D-01

Extinction (Mm -1)

20% W > 133

0

50

100

150

200

250

300

J-00

F-00

M-00

A-00

M-00

J-00J-00

A-00S-00

O-00N-00

D-00

Extinction (Mm -1)

20% W > 96

0

50

100

150

200

250

300

J-03

F-03

M-03

A-03

M-03

J-03J-03

A-03S-03O-03N-03

D-03

Extinction (Mm -1)

20% W > 116

0

50

100

150

200

250

300

J-04

F-04

M-04

A-04

M-04

J-04

J-04

A-04

S-04

O-04

N-04D-04

Extinction (Mm -1)

Appendix J - 169
e 

v. As the science is 

refined, the estimate of natural visibility condition can be refined. 

at “Common Sense” Coastal Knowledge Appears to be 

ty is 

ts 

ore 

ght and this meteorological influence is incorporated in the IMPROVE equation. 

p 2007, fog 

. This measure does not address aerosol contribution to visibility 

impairment. 

y 

in 

ulatory 

basis for evaluating a state’s progress in improving visibility in the Class I areas. 

5)

bles 

 CAIR, CAMR, the NOX Sip call and other regulations and planned 

mission reductions. 

y improvements projected for 2018 are not as 

y 

s 

 

Using the VISTAS Na+ measurements for IMPROVE samples for 2004 from Cap

Romain (average of 0.73 μg/m3, less than the 1.3 value offered in the Chamber’s 

comments), natural background visibility might increase 1.0 to 1.5 d

4) The Chamber is concerned th

Missing from the Equations 

The Chamber’s comments that weather is not considered in the IMPROVE equation and

in modeling are incorrect. The entire year of 2002 was modeled in the meteorological, 

emissions and air quality models, including periods of rain and fog. Relative humidi

used as a factor in the calculation of light extinction for sulfate, nitrate, and sea salt 

because relative humidity increases the efficiency of light scattering by these componen

that absorb water. At higher relative humidity the same particle mass will scatter m

li

Relative humidity is routinely measured at Cape Romain in conjunction with the 

nephelopmeter. Using relative humidity greater than 90% as an indicator when fog or rain

affected visibility, we can estimate that during the period Jan 2004 through Se

or rain likely affected visibility roughly 40% of the hours of operation of the 

nephelometer

The objective of the Regional Haze Rule is to mitigate man-made impairment of visibilit

on national parks and wilderness areas, thus the focus is on that component of visibility 

impairment that is caused by human emissions. EPA Guidance for Tracking Progress 

under the Regional Haze Rule14 defines the approach to be used to calculate visibility 

based on aerosol mass, extinction efficiency, and relative humidity. This is the reg

Planned Emission Reductions

Emissions summaries for 2002 and 2018 are provided in Appendix D.2.a. Several ta

summarize the emissions reductions from existing regulations including reductions 

expected as a result of

e

6) The Chamber is concerned that visibilit

large as projected emission reductions.

The air quality model is first run for 2002 using 2002 inventories and 2002 meteorolog

and model performance is demonstrated. Then the model is run using using the 2002 

meteorology with 2018 inventory to project the changes in air quality in 2018 due solely 

to changes in emissions (holding meteorology with all the seasonal variations the same as

2002). The change in emissions from 2002 to 2018 is reflected in changes in air quality 

for every day of the year. EPA guidance defines that the calculation of visibility change

14 EPA-454/B-03-004, September 2003 

Appendix J - 170
for 2018 will be based on the average of the changes for each of the 20% worst or 20% 

2 

sponse on all 20% worst visibility days is less than average SO2 

missions reductions (see Figure 2). These seasonal factors have been considered in the 

2. Modeled Changes in Light Extinction in response to 2018 emissions changes, 

r each component of PM2.5 mass, for the 20% Worst Visibility Days at Cape Romain in 

7) ot 

best visibility days as defined by aerosol loadings in 2002. 

The conversion of SO2 to SO4 is temperature and oxidant dependent and is much more 

efficient during hot summer conditions than during the cooler winter months. Because 

several of the days determined by IMPROVE methods to be the 20% worst days in 200

are winter days, and because conversion of SO2 to SO4 is less efficient on cooler days, 

the average sulfate re

e

VISTAS analyses. 

Modeled Responses to 2018 Base G2a Emissions on 20% Haziest Days

Cape Romain, SC

-120

-100

-80

-60

-40

-20

0

20

Figure 

fo

2002. 

The Chamber is concerned that naturally occurring ammonia and sulfates are n

considered. 

Ammonium sulfate is considered as part of natural background visibility in the EPA 

Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule15. 

Average natural concentrations of ammonium sulfate were estimated to be 0.23 μg/m3 

 

15 EPA-45A/B-03-005, September 2003. 

17 29 44 47 53 110 122 155 158 182 185 188 197 200 206 212 236 254 257 260 293 296 299 341 Avg

Delta Bext (1/Mm)

Julian Day

bCM

bSOIL

bEC

bOC

bNO3

bSO4

Modeled Responses to 2018 Base G2a Emissions on 20% Haziest Days

Cape Romain, SC

-120

-100

-80

-60

-40

-20

0

20

17 29 44 47 53 110 122 155 158 182 185 188 197 200 206 212 236 254 257 260 293 296 299 341 Avg

Delta Bext (1/Mm)

bCM

bSOIL

bEC

bOC

bNO3

bSO4

Julian Day

Appendix J - 171
with a range of 0.12 to 0.46 μg/m3. The GEOS-Chem global chemistry model16

estimated that annual average natural background concentrations of ammonium sulfate in

the eastern US were 0.11 μg/m3, very similar to that used in EPA’s original estimate. The

estimate for natural background ammonium sulfate on the 20% worst visibility days base

on the revised methods to calculate natural conditions using the new IMPROVE equatio

is0.29 μg/m3. These values can be compared to ambient concentrations of ammonium 

sulfate measured by IMPROVE at Cape Romain on the 20% worst visibility days in 20

that ranged from 4.4 to 17.8 μg/m3. Fin

d 

n 

02 

e and coarse soils and volcanoes are natural 

urces for sulfate, as is the ocean. None of these natural sources are significant 

8)

c 

re used to 

efine the frequency that air masses that arrived at Cape Romain traveled over specific 

9)

e Romain area dominate any 

natural sources of SO2 in the area. Reductions in SO2 emissions will result in air quality, 

10)

l 

. 

arbon 

 to 

s 

g 

 

so

compared to current anthropogenic SO2 emissions. 

The Chamber is concerned that Back Trajectories Are Not Appropriate for 

Conducting Area of Influence Analysis.

The objective of the SO2 Area of Influence analysis was to understand which geographi

area was most likely to influence Cape Romain. Back trajectory analyses we

d

geographic areas. This analytical approach is appropriate for that purpose. 

The Chamber is concerned that a Cause-Effect Relationship between Ammonium

Sulfate and Visibility Has Not Been Clearly Established.

South Carolina respectfully disagrees with the Chamber. The air quality benefits that 

have resulted from SO2 emissions reductions to date have been well documented and 

were discussed under item 2 above. There is always more to learn but it can not be 

disputed that anthropogenic emissions of SO2 in the Cap

visibility, and public health benefits for South Carolina. 

The Chamber is concerned that Sources of Organic Carbon and their Impact on

Visibility Appear to be Incomplete.

Sources of organic carbon include natural vegetative emissions, vegetative detritus, 

prescribed fire, wild fire, land clearing, residential wood combustion, gasoline and diese

engines, industrial point sources, marine traffic, coal combustion, cooking and road dust

VISTAS is investing considerable effort to better understand sources of organic c

including special monitoring studies, improvements to the regional air quality model

better characterize secondary aerosol formation, and improvements in emissions 

inventories. VISTAS funded special sampling for carbon at 5 sites, including Cape 

Romain for April 2004 through May 2005. Chemical Mass Balance and Positive Matrix 

Factorization analyses are underway now to determine relative source contributions to 

measured organic carbon. Analyses of carbon 14 isotope in carbon samples indicate that 

modern sources of carbon (vegetative emissions, vegetative detritus, biomass burning, 

cooking) are more important than fossil sources (gasoline, diesel, coal, oil), accounting for 

60 to 80% of measured carbon throughout the year. Monitoring data in Figure 1 of thi

response indicate likely impacts from fires in spring and fall 2000, June 2001, sprin

rk, R.J., Jacob, D.J., Field, B.D., Yantosca, R.M., Chin, M. 2003. Natural and Transboundary Pollution 

ences on Sulfate-Nitrate-Ammonium Aerosols in the United States and Implications for Natural Visibility.

16 Pa

Influ 

J. Geophysical Research, 108, D12, 4355. 

Appendix J - 172
 8 

ooking) are more important than fossil sources (gasoline, diesel, coal, oil), accounting for 

 

. 

e 

11)

 as 

 procedures and quality assurance project plans . 

ower, shelter, and road access are required to operate the monitor. The incremental 

contributions of road dust, vehicle exhaust, recreational boating and vegetative emissions 

from previous emissions reductions 

and the scientific data bases used to develop the State Implementation Plan have been well 

documented and reviewed. There are always opportunities to improve our understanding and 

strategies to improve air quality as we move forward toward the goal of no man made 

impairment to visibility by 2064. For this first implementation period the data and science 

presented is sufficient to justify the conclusions drawn. 

 

c

60 to 80% of measured carbon throughout the year. Monitoring data in Figure 1 of this 

response indicate likely impacts from fires in spring and fall 2000, June 2001, spring 

2002, and April 2004. It is likely that eight of the 100+ 20% worst days in 2000-2004 

were impacted by fire episodes. Fire may have been a factor on additional days. 

EPA guidance estimates annual average natural background conditions for organic carbon

as 1.4 μg/m3 with a range of 0.7 to 2.8 μg/m3. Using the new IMPROVE equation, the 

annual average for organic carbon would be 1.8 μg/m3 with a range of 0.8 to 3.6 μg/m3.

These estimates assume carbon from vegetative emissions, natural fires, and the ocean

There is still much to learn about source contributions to organic carbon in the southeast

and this will be one of the areas of focus for future regional haze analyses. The majority 

of 20% worst visibility in the 2000-2004 baseline period are dominated by SO4 and th

focus in this SIP on SO2 emissions is appropriate. 

 The Chamber is concerned about the reliability of data collected at Cape Romain

The Cape Romain IMPROVE monitor meets citing criteria for the IMPROVE network

described in the standard operating 17

P

in the vicinity of the Cape Romain monitor can be estimated in the future. As seen in the 

2000-2004 baseline data for Cape Romain in Figure 1, soil and coarse mass are minor 

contributors to light extinction. 

In summary, air quality benefits have been demonstrated 

17 http://vista.cira.colostate.edu/improve/Publications/publications.htm 

Appendix J - 173
SCPPA South Carolina Pulp & Paper Association 

Post Off~ce Box ? 18005. Cl,drlcston. SC 29423 

November 12,2007 

Ms. Maeve S. R. Mason 

SC DHEC 

AbitibiBowater 2600 ~~11 street 

Inc. 

Columbia, SC 29201 

BUREAU OF Al h ii WLlPl 

Re: South Carolina State Implementation Plan Revisions 

Domtar Section 169A of the Clean Air Act ("Regional Haze Rule") 

International 

Dear Ms. Mason: 

Paper The following comments are provided on behalf of the South Carolina Pulp and Paper 

Association (SCPPA) regarding the proposed changes to SC State Implementation Plan (SIP) to 

address Section 169A of the Clean Air Act ("Regional Haze Rule"). 

MeadWestvaco 

Corporation SCPPA members operate seven major manufacturing facilities in South Carolina and provide 

employment for over 13,000 South Carolinians. The comments provided in this submittal do 

not preclude member companies from submitting additional comments directly or through other 

associations with which they are affiliated. In particular, many SCPPA member companies are 

Sonoco 

part of the Southeast Visibility Industry Coalition ("SEVIC"). The comments submitted by 

SEVIC have been reviewed and are generally supported by SCPPA, and as such, are included 

by reference. 

Smurf~t Stone 

Conta~ner 

Corporation SCPPA members support the improvement of air quality in South Carolina, including 

improvements in regional haze. Our members are equally concerned that the methodologies, 

models and data used in establishing goals are reasonable, attainable and cost effective. The 

SCPPA's concerns and comments are provided in the spirit of achieving the goals of the 

Regional Haze Rule without unnecessary impact on business and industry in South Carolina. 

SCPPA is concerned about the time allowed for review and comment of the SIP. 

The proposed SIP consists of approximately 5,000 pages (e.g. SIP and 39 appendices) of highly 

complex technical theory expressed in mathematical relationships (models). This material was 

provided for review on SC DHEC's website beginning on November 15, 2007. The material, 

much of it developed and/or revised within the last few months, forms the basis for regulatory 

decisions which may potentially require hundreds of millions of dollars in expense over the 

next six decades in order to achieve the stated goal of the Regional Haze Rule (e.g., returning 

visibility at the Cape Romain Class I area to that which existed prior to man's presence). 

Et11~irot1nrentczl concern with a cooperati\,r, c<ffi~rr. 

Appendix J - 174
Ms. Maeve S. R. Mason 

December 12,2007 

Page 2 

SCPPA has serious concerns that in preparing the proposed SIP revisions, SC DHEC has 

relied almost entirely on new and inadequately tested visibility methodologies, models 

and data developed by the Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS) and the Interagency Monitoring of Protective Visual Environments 

(IMPROVE) organizations. The methodologies, models and data are used to establish 

theoretical cause-and-effect-relationships between 1) current visibility, 2) man-made 

emissions, 3) naturally-occurring emissions, and 4) "naturally occurring" visibility 

conditions. 

To our knowledge, there has been some scientific peer review of certain aspects of these 

procedures, but in many cases the testing has not focused upon visibility characterization. 

For example, CALPUFF has been peer reviewed for predictions of concentrations of 

criteria pollutants, but not for chemical transformation and visibility calculations. The 

IMPROVE equation has been tested with current atmospheric pollutant loadings, but not 

for projecting future cases with much different characteristics. In short, there are no 

experimental databases available to test the consequences of what the Regional Haze 

Rule is mandating - a massive reduction in the nation's pollutant emissions. As noted 

below, such testing will be possible only after the first milestone period in the Regional 

Haze Rule implementation is completed and should be done before any further RHR 

milestones are attempted. 

This evaluation has not been possible to date because of the lack of massive emission 

reductions within a short period. The emission reductions that will occur as a result of 

CAR, CAMR, NOx SIP call, etc. present a unique and essential opportunity for a 

complete model evaluation process relative to the Regional Haze Rule goals. The testing 

results should be submitted to the public for review and comment before a conclusion of 

adequate model performance is possible. Likewise, the regulated community should not 

be presented additional information requests under the Regional Haze Rule until this 

model performance evaluation is complete. 

SCPPA supports SC DHEC's approach and conclusions regarding Best Available 

Retrofit Technology (BART). 

SCPPA appreciates the thousands of hours expended by SC DHEC's' management and 

staff on the Regional Haze SIP. We understand that SC DHEC has been an active 

member of VISTAS, along with other southeastern states, EPA Region 4 and the Federal 

Land Managers. We understand that SC DHEC is encouraged to consult with these 

organizations in making decisions relative to their SIP, but is not required to utilize their 

input, especially where it is found to be inaccurate or deficient in some manner. 

SCPPA supports the decisions that SC DHEC has made with regard to the unique local 

conditions that exist in coastal environments. Where it has been necessary to depart form 

VISTASIIMPROVE guidance for reasons of accuracy andlor questionable data quality, 

SC DHEC has appropriately done so. The errors and omissions, especially regarding the 

data quality and visibility impacts of naturally-occurring sea salt, would have gone 

uncorrected had SC DHEC not stepped forward and applied its own stringent quality 

guidelines and made necessary corrections. As a result, SCPPA compliments and 

Environmental concern with a coopel-ative efort. 

Appendix J - 175
Ms. Maeve S. R. Mason 

December 12,2007 

Page 3 

supports SC DHEC on its analysis and decisions related to the BART portions of the 

Regional Haze Rule. 

SCPPA asks that clarification be provided on the emissions data used in various 

sections of the SIP (e.g. BART eligibility, modeling, and deciview impacts). 

It should be noted that Appendix H.4 contains numbers used for BART applicability 

determinations and not the more accurate actual emission rates used for modeling 

purposes. Also, there appears to be inconsistencies in the reported deciview impacts 

listed on pages 82 and 89 of the draft SIP. 

SCPPA is concerned about the uncertainties in the uniform rate of progress 

determinations. 

Based on a preliminary review limited by the time available in this review period, 

SCPPA has identified the following areas of uncertainty in the methodologies, models 

and data and requests that EPA formally address and resolve each before any uniform 

rate of progress (e.g., glidepath) is accepted for regulatory purposes. This review will be 

especially important to be completed and corrective actions taken before any hture 

Regional Haze Rule-related emissions reductions are considered. 

1. "Common Sense" Coastal Knowledge Appears to be Missing from the 

Equations -Weather (in the form of natural obscuration) is clearly the 

predominant factor affecting visibility at Cape Romain, yet it is not addressed 

anywhere in the SIP or supporting documents. The marine environment is vastly 

different from the western mountains and upland plains where many of the 

IMPROVE measurements were taken and used by the organization that developed 

the visibility models. The majority of the Cape Romain National Wildlife Refuge 

consists of water which represents an enormous heat source in the colder months 

and heat sink in the warm months. During both seasons, the large mass of water 

has a considerable affect on local weather patterns and visibility through naturally 

occurring fog, local showers and thunderstorms, morning inversions (especially 

during the colder months), and diurnal coastal wind patterns. These conditions 

either do not exist or are significantly different from conditions in the arid and 

semi-arid western U.S. Weather impacts are not considered in 1) the models or 2) 

as natural causes of visibility impairment (e.g., the 20% worst visibility days). 

Not considering the single most significant cause of visibility impairment 

(especially for the 20% worst visibility days) skews the data, the determination of 

"natural background visibility," and the determination of Uniform Rate of 

Progress. 

2. Hurricanes, Storms at Sea, and Breakers along the Coast Suspend Sea Salt in 

the Atmosphere- Second to weather, suspended sea salt is known to be a 

significant contributor to natural visibility impairment in coastal and near-coastal 

areas. However, it does not appear sea salt was considered in determining either 

the natural background conditions or Uniform Rate of Progress (glidepath) for 

Environmental concern with a cooperative effort. 

Appendix J - 176
Ms. Maeve S. R. Mason 

December 12,2007 

Page 4 

Cape Romain. Page 22 contains the statement "As Figure 2.4-2 indicates, NaCl 

contributions to visibility impairment are most important on the 20 percent 

clearest days when sulfate and POM levels are low. NaCl levels do not contribute 

significantly to visibility on the 20 percent worst visibility days." These 

statements are counter-intuitive and indicate the methodologies, models and data 

developed may be completely missing the mark as far as reflecting the actual 

conditions that occur (and historically occurred) in coastal Class I areas such as 

Cape Romain. (Figure 2.4-3 on the page 23 appears to acknowledge the impact of 

sea salt on the 20% worst visibility days and contradict the conclusion at the 

bottom of page 22.) 

3. Sea Salt Data Collection - The analytical methods used at IMPROVE 

monitoring sites have been inappropriate for accurately measuring sodium and 

chloride that is essential for accurate determinations of Sea Salt concentrations. 

The result has been a database of very poor (e.g., unusable) quality when 

compared to EPA7s own data quality guidance. The best analytical method for 

determining sea salt is reported by analytical experts to be Neutron Activation. 

Although this technique is proven, available and affordable, it has not been 

utilized. SCPPA recommends sea salt measurements using Neutron Activation 

should begin immediately. Additionally, we recommend that EPA should 

immediately discontinue requiring that states use existing poor quality data as 

input to the New IMPROVE model. Doing so is a direct violation of the 

Agency's data quality guidelines. The age-old adage that the "results of the 

model are only as good as the quality of the input" certainly applies in this case. 

4. Glidepath Correction to Reflect Accurate Sea Salt Measurements - Once 

accurate sea salt concentrations are determined using the appropriate techniques, 

these should be used as input to the models. Additionally, the Uniform Rate of 

Progress (e.g., glidepath) should be adjusted to properly reflect the impact of sea 

salt on naturally-occumng visibility. Doing so has the potential to alter the end 

point of the glidepath considerably, and will more accurately reflect natural 

conditions in this coastal environment. For example, earlier work performed by 

VISTAS using a very realistic sea salt concentration of 1.30 ug/m3 (sodium 

method) for Cape Romain resulted in a natural background condition of 14.1 

deciview instead of the 12.1 deciview currently reported in the draft SIP for the 

average 20% worst days. The 12.1 deciview is based on a sea salt concentration 

of 0.2 ug/m3, which is significantly lower than coastal area sea salt 

concentrations reported in the scientific literature. 

5. Planned Emission Reductions - Since visibility is dependent to some extent on 

emissions of SOz, NO, and fine particulates, the SIP should provide a table and 

bar chart clearly and simply showing chronological reductions expected as a 

result of the Clean Air Interstate Rule, the Clean Air Mercury Rule, the NO, SIP 

Call and other regulations and planned emission reductions between now and 

2064. These reductions can then be compared to visibility improvement predicted 

by the models. 

Environmental concern with a coopel.ative eflort 

Appendix J - 177
Ms. Maeve S. R. Mason 

December 12,2007 

Page 5 

6. Visibility Improvement Does Not Calibrate to Emission Reductions - After 

plots of the emission reductions (see #5 above) are made available, the visibility 

model should be calibrated to determine if it is accurately reflecting the visibility 

improvement resulting from planned emission reductions. SCPPA understands 

that emissions will decrease by 73% by 2018, but the model only predicts a 26% 

reduction in haze. The model appears to be inaccurate to the point that one could 

easily conclude the 2064 goal can never be achieved. SCPPA is concerned that 

successive rounds of costly emission reductions may be mandated for South 

Carolina businesses in attempts to achieve an erroneously calculated and 

unattainable goal. 

SCPPA recommends that before any future emission reductions are mandated in 

the implementation of the Regional Haze Rule, the effects of the first round of 

reductions should first be evaluated with the modeling tools to assure that the 

observed visibility improvements are accurately depicted by the models. Since 

the emission reductions will not be completely in effect until perhaps 2014 and it 

will take perhaps 3-4 years to get reliable measurements of the benefits, we 

believe that the initial assessment of the modeling tools and corrections will not 

be completed until 2020. At that time, if we have modeling tools that adequately 

replicate the expected improvements in visibility, then they may be used for 

future assessments of emission reductions required to stay on the glidepath. 

Otherwise, the modeling tools will need to be adjusted to achieve adequate 

performance, and only after that will hture emission reduction assessments be 

feasible. 

7. Naturally-Occurring Ammonia and Sulfates are Not Considered - In Section 

2.4 (page 20), ammonium sulfate is identified as the largest contributor to haze at 

Cape Romain. All ammonium sulfate is apparently assumed to be the result of 

man-made emissions. SCPPA questions why the contribution of natural biogenic 

sources of ammonia and sulfates are not considered when determining naturallyoccurring background visibility. Natural decay of the abundant vegetation in 

Cape Romain's saltwater marshes releases significant quantities of ammonia as a 

result of the reducing environment and the anaerobic biodegradation that takes 

place in the soils and marine sediments. Likewise, sulfates are released in large 

quantities from both sea water (where sulfate ions comprise 7.7 wt% of the total 

salts present in all seawater) and from phytoplankton that release large amounts of 

sulfates to the atmosphere. Again, by not recognizing these natural sources of 

haze when establishing the Uniform Rate of Progress end point, severe financial 

burden will likely be placed on business and industry in hture attempts to achieve 

unrealistically low visibility goals. 

8. Back Trajectories Are Not Appropriate for Conducting Area of Influence 

Analysis - The back trajectory modeling approach used to determine an Area of 

Influence is not appropriate and should not be used. Other approved modeling 

techniques would provide much more detailed information, and better represent 

the dispersion of industrial and other plumes. It is commonly known that grid 

based modeling techniques such as CMAQ, which uses large grid sizes and many 

Environmental concern with a cooperative effort. 

Appendix J - 178
Ms. Maeve S. R. Mason 

December 12,2007 

Page 6 

subjective assumptions, do a poor job of evaluating point source plumes. 

SCPPA's concern about using back trajectories have been discussed in other 

scientific venues which document the technical shortcomings of using back 

trajectories over long distances and over extended periods of time. 

9. Cause-Effect Relationship between Ammonium Sulfate and Visibility Has 

Not Been Clearly Established - The fact that high sulfates (and other speciated 

salts) were measured on the particulate filters at Cape Romain during the 20% 

worst visibility days (page 20) does not confirm a cause-effect relationship as 

suggested. It is highly likely that the same naturally-occurring conditions that 

cause the visibility impairment, such as an inversion for instance, would trap and 

concentrate naturally-occuning sulfates and ammonia released from plankton and 

marine marsh sediments. Suggesting conclusively that the elevated 

concentrations of ammonium sulfate are 1) all from man-made emission sources, 

and 2) are the cause of the visibility reduction rather than the result of naturallyoccurring atmospheric conditions are unsupported. EPA must prove the science 

behind this and the many other theories used in the methodologies, models and 

data before they are suitable for use for regulatory purposes such as 

implementation of EPA's Regional Haze Rule. 

10. The Sources of Organic Carbon and their Impact on Visibility Appear to be 

Incomplete - Section 2.4 (page 22) states that Particulate Organic Matter (POM) 

is the second most important contributor to regional haze at Cape Romain. The 

source of this haze, naturally occurring or man-made, is not clearly explained. It 

is common local knowledge that the indigenous local pine forests and both the 

natural and prescribed burning of nearby marsh grasses for enhanced wildlife 

management, results in significant emissions of organic carbon. Long-leaf 

(loblolly) pine forests predominate in the upland reaches of Cape Romain, and 

this species requires fire to sustain its life-cycle. If one assumes that lightninginduced natural fires occurred prior to man's existence, most of the POM 

measured today should also be considered naturally-occurring. We understand 

that Carbon-14 studies at Class I areas in the Southeast support this and have 

generally found that about 80 to 90% of the carbon is of modem origin (i.e., non 

fossil, hence not from petroleum and coal). Attributing organic carbon to manmade emissions and not reflecting this in the Uniform Further Progress 

(glidepath) calculations is inaccurate and misleading and must be corrected. 

SCPPA recommendation is that the visibility associated with natural conditions 

needs to be totally re-evaluated to account for natural and non-USA sources of the 

particulates that cause visibility impairment before any future emission reductions 

are considered under the Regional Haze Rule. The findings of what constitute 

natural conditions should be submitted to the public before review and comment 

before they are considered final. 

11. Reliability of Data Collected at Cape Romain - SCPPA has considerable 

concerns about the quality of air quality data collected at the IMPROVE site 

located at Cape Romain. This data is used as the basis for virtually all of the 

regulatory conclusions regarding current and natural conditions. This monitoring 

En\.ironrnental concern with a cooperative cffoor-t 

Appendix J - 179
Ms. Maeve S. R. Mason 

December 12,2007 

Page 7 

site was subjected to a review of monitoring sites in 2007 by a stakeholder group 

which included members of the SCPPA, SC DHEC and NGO's. The site has 

several identified deficiencies, including: 

a. The monitor is located only 47 feet from a dirt road leading to the NWR's 

maintenance complex. Particulate measurements used for RHR 

implementation need to be extremely accuratelprecise if they are to be 

used in determining "natural background conditions" and "glidepaths," yet 

measurements at this monitor are potentially skewed by emissions from 

the dirt roadway and other nearby sources. 

b. Likewise, organic carbon measurements are presented as a primary cause 

for regional haze, yet the Cape Romain NWR maintenance shop building 

and yard are located only 330 feet from the monitor. Heavy diesel 

equipment are housed, fueled, operated and repaired at this location and 

must travel directly past the monitor when used within the NWR, 

potentially skewing organic carbon measurements. 

c. The Cape Romain monitor is located 0.2 miles from the Intracoastal 

Waterway. This section of the ICW receives very heavy local recreational 

boat traffic as well as considerable traffic from large yachts and 

commercial vessels being transported up and down the Atlantic coast. The 

close proximity to the monitor can bias the very precise measurement of 

particulates, organic carbon, sulfate and other parameters measured. 

d. A large stand of pine trees is located only 32 feet from the monitor, 

contributing organic carbon and particulates that would cause the data to 

be potentially unusable for regional haze calculations. 

e. SCPPA believes there are much better locations to monitor air quality 

within the Cape Romain NWF. The locations may not be as accessible 

and convenient, but the accuracy of the data must be the paramount 

consideration given the dollar magnitude of regulatory decisions that may 

result from the use of the collected data. 

Conclusions 

SCPPA complements SC DHEC on the extensive effort put forward to support VISTAS 

and the other stakeholder groups participating in the Regional Haze Rule implementation 

in South Carolina. The goal of the Regional Haze Rule is one that SCPPA and its 

members support. 

Creating a Regional Planning Organization such as VISTAS, however, does not relieve 

EPA or SC DHEC from their mandated responsibility to use sound, proven science and 

reliable data in making regulatory decisions. Despite the existence of over 5,000 pages of 

supporting documentation provided for review; we find the methodologies, models and 

data may have serious shortcomings and lack of appropriate evaluation. We do not feel 

this is the responsibility of the state agency, but rather the responsibility of EPA, the 

Environmental concerx with a coopei.ative effort 

Appendix J - 180
Ms. Maeve S. R. Mason 

December 12,2007 

Page 8 

FLMs and the organizations created to assist in the implement the Regional Haze Rule 

(e.g., VISTAS, IMPROVE, etc.). 

Until an extensive level of review, verification and quality assurance is begun in about 10 

years (after implementation of CAIR and additional measurements), SCPPA contends 

that the methodologies, models and data are not suitably tested for future analysis of 

visibility impairment, and should not be used in future regulatory decision-making 

associated with the Regional Haze Rule. 

If you have any questions, please feel free to call me at (843) 745-3 139 or electronically 

at dam20@meadwestvaco.com. 

Sincerely, 

Duane Mummert, P. E. 

Chair, SC Pulp and Paper Association 

cc: SCPPA Members 

Eizvironmental concern with a cooperative effort. 

Appendix J - 181
BOARD: 

Henry C. Scott 

M. David Mitchell, MD 

BOARD: 

Paul C. Aughtry, 111 

Chairman 

Edwin H. Cooper, I11 

Vice Chairman 

Steven G. Kisner 

Secretary C. Earl Hunter, Commissioner 

Promoting and protecting the henlth cd'the public and the twz~ironrrrent 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

December 2 1,2007 

Duane Mummert 

SC Pulp & Paper Association 

Post Office Box 1 18005 

Charleston, SC 29423 

Re: Regional Haze State Implementation Plan (SIP) Comments 

Dear Mr. Mummert: 

South Carolina has prepared a draft SIP to address visibility and regional haze issues for the 

State's Class I Federal area, the Cape Romain Wilderness area. The Department submitted a 

notice to the South Carolina State Register in October 2007, soliciting comments on the draft 

SIP. 

On December 13, 2007, the Department received comments from the South Carolina Pulp & 

Paper Association (SCPPA) on the State's per-hearing draft State Implementation Plan (SIP). 

These comments were organized into several sections and called into question the State's 

treatment of a variety of substantive issues, including the interpretation of sea salt in the new 

IMPROVE equation, the State's approach and conclusion regarding Best Available Retrofit 

Technology (BART) and planned emission reductions, the uniform rate of progress, and the 

general reliability of data collected. 

The Department appreciates the depth and specificity of the SCPPA's review of the State's SIP. 

The attached document serves to specifically address the concerns and comments presented by 

the SCPPA. 

The Department has considered these comments as well as additional comments submitted by 

other interested parties. In reviewing these comments, the Department has evaluated the 

significance of each in terms of addressing visibility impairment and, where appropriate, has 

revised the SIP accordingly. 

The final SIP package was due to the Environmental Protection Agency (EPA) on December 17, 

2007. Due in part to the comments received by the SCPPA, the Department has delayed its 

submittal of the State's SIP to the EPA to provide time for adequate comment response. 

However, the Department intends to submit its final SIP package to the EPA by December 21, 

2007. The Department hopes that the changes made to the final SIP package serve to address the 

comments/concerns that were submitted during the public comment period. The Department 

remains committed to improving visibility in the region and appreciates the opportunity to work 

with SCPPA to produce the best possible SIP. 

SOUTH C A R O L I N A D E P A R T M E N T OF HEALTH AND ENVIRONMENTAL CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

Appendix J - 182
Mr. Mummert 

December 2 1,2007 

Page 2 

Should you have any further questions concerning South Carolina's regional haze SIP 

development, please feel free to contact Maeve Mason of my staff at (803) 898-2230 or 

masonmr@,dhec. sc. gov. 

Sincerely 

Robert 

Mp& J'. Brown, Jr., Director 

Division of Air Planning, Development & Outreach 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Renee Shealy, Assistant Bureau Chief, SCDHEC 

Stacey Gardner, Manager, Regulation Development Section, SCDHEC 

Pat Brewer, VISTAS Technical Advisor 

Appendix J - 183
Responses to Comments from SC Pulp & Paper Association (SCPPA) 

Implementation of the Regional Haze Rule is planned over the sixty-four year period from 

2000 to 2064. Our understanding of emissions inventories and visibility will improve over 

this same period. This first regional haze state implementation plan follows the best 

guidance and science available in 2007. The science will continue to be reviewed and 

updated as better information is available and these improvements will be considered in the 

2012 interim review. 

SC has reviewed SCPPA’s concerns and offers the following technical responses. 

1) SCPPA is concerned about the time allowed for review and comment of the SIP and 

that the scientific basis is new and inadequately tested.

VISTAS has provided an open stakeholder process since 2002 and members of the 

SCPPA have participated in VISTAS. All of the methods and results have been provided 

for peer review by the scientific community and by VISTAS participants as they were 

developed. Open dialog has been encouraged and SCPPA members have been invited to 

participate. 

The scientific basis of the South Carolina State Implementation Plan has been well 

documented. Several scientific journal articles have been published in peer review 

journals documenting monitoring data analyses, evaluation of natural visibility conditions, 

performance of emissions and air quality models, and air quality responses to emissions 

reductions. These published articles1

,

2

,

3

,

4

,

5

,

6

 were included in the SC SIP Appendices to

demonstrate the effort that has been made to assure scientifically defensible analyses are 

used in the State Implementation Plan. 

 

The IMPROVE monitoring network was established in 1985 to implement a long term 

monitoring program to establish the current visibility conditions, track changes in 

visibility, and determine causes of haze in national parks and wilderness areas. IMPROVE 

1

 Brewer, P. F., and Adhloch, J. 2005. Trends in Speciated Fine Particulate Matter and Visibility across 

Monitoring Networks in the Southeastern United States. J. Air & Waste Management Association 55:1663-1674 2

 Tombach, I. and Brewer, P. 2005. Natural Background Visibility and Regional Haze Goals in the 

Southeastern United States. J. Air & Waste Management Association 55:1600-1620. 3

 Morris, R. E., Koo, B, Guenther, A., Yarwood, G., McNally, D., Tesche, T.W., Tonnessen, G., Boylan, J. and 

Brewer, P. 2006. Model sensitivity evaluation for organic carbon using two multi-pollutant air quality models 

that simulate regional haze in the southeastern United States. Atmospheric Environment 40: 4960-4972. 4

 Morris, R. E., McNally, D. E., Tesche, T.W., Tonnessen, G., Boylan, J. W., and Brewer, P. 2005. Preliminary 

Evaluation of the Community Multiscale Air Quality Model for 2002 over the Southeastern United States. J. Air 

& Waste Management Association 55:1694-1708. 5

 Tesche, T.W., Morris, R. E., Kou, B. Guenther, A., McNally, D. E., Tonnessen, G., Boylan, J. W., and Brewer, 

P. 2006. Diagnostic Model Performance Evaluation Using Multiple Air Quality Models for Simulating Ozone, 

Particulate Matter and Regional Haze in the Southeastern U. S. Atmospheric Environment 40: 4906-4919. 6

 Odman, M. T., Hu, Y., Unal, A., Russell, A. G. and Boylan, J. W, 2007. Determining the sources of regional 

haze in the Southeastern U.S. using the CMAQ model. Journal of Applied Meteorology and Climatology, 46, 

11, pp. 1731-1743, 

Appendix J - 184
currently operates monitors at 110 sites representative of 156 Class I areas, with an 

additional 49 sites operated following IMPROVE protocol and funded by other federal, 

state, and tribal organizations. IMPROVE has rigorous monitoring standard operating 

procedures and data quality standards7

. The SCPPA’s statement that SC has relied on 

new and inadequately tested methodologies is incorrect. 

e 

 nitrate 

deposition and ozone. 

 naturally occurring sea salt at Cape Romain has not been 

her 

e comments then cite sections of the Narrative 

at discuss how sea salt was addressed. 

how 

n of both natural background and current conditions in the new 

PROVE equation12. 

f NaCl. 

 

2) SCPPA incorrectly states that there have been no previous massive reductions in 

pollutants emissions that could be used to evaluate air quality benefits. In fact, SO2 

reductions under Title IV of the 1990 Clean Air Act Amendments have resulted in 

significant reductions in sulfate deposition8

 and aerosol loadings. Visibility 

improvements in response to SO2 emissions reductions have been documented by th

IMPROVE monitoring network9

,

10. As discussed in Appendix B, Conceptual 

Description, IMPROVE data demonstrates visibility improvement at 8 sites in the 

VISTAS region, including Cape Romain, over the period 1995 to 2004. In addition to 

SO2 emissions reductions, NOx emissions reductions under Title IV and under the NOx 

State Implementation Plan (SIP) Call have resulted in significant reductions in

8

3) SCPPA is concerned that

adequately considered. 

The SCPPA’s statement on page 4 that sea salt was not considered in determining eit

the natural background conditions or Uniform Rate of Progress (glidepath) for Cape 

Romain is incorrect and confusing since th

th

The EPA Guidance for Tracking Progress in under the Regional Haze Rule11 defines 

current and natural background visibility conditions should be calculated to derive a

uniform rate of progress toward natural background visibility in 2064. SC and the 

VISTAS states chose to use the new IMPROVE equation and the new calculation of 

natural conditions to define the uniform rate of progress for Cape Romain. Sea salt is 

included in the calculatio

IM

Sea salt is composed primarily of sodium chloride, NaCl. IMPROVE uses Cl-, measured 

by ion chromatography of samples collected on the Nylon filter, as an indicator o

Cl- may volatize off the filter and may under represent sea salt values. Routine 

7

 IMPROVE Standard Operating Procedures and IMPROVE Aerosol Quality Assurance Project Plan 

http://vista.cira.colostate.edu/improve/Publications/publications.htm 

8

 Dennis, R. Haeuber, R., Blett, T., Cosby, J., Driscoll, C., Sickles, J., Johston, J. 2007. Sulfur and Nitrogen 

Deposition on Ecosystems in the United States. Environmental Management, Dec 2007, pp. 12-17. 9

 Malm, W.C., B.A.Schichtel, R.B. Ames, and K.A. Gebhart, 2002. A 10-year spatial and temporal trend of 

sulfate across the United States, J. Geophysical Research, 107. 10Spatial and Seasonal Patterns and Temporal Variability of Haze and Its Constitutes in the United States. 2006. 

IMPROVE Report IV. Cooperative Institute for Research in the Atmosphere. 

11 EPA-454/B-03-004, September 2003 

12 Pitchford, M., Malm, W., Schichtel, B., Kumar, N, Lowenthal, D., Hand, J. 2006. Revised Algorithm for 

Estimating Light Extinction from IMPROVE Particle Speciation Data. J Air & Waste Management Assoc. 

Appendix J - 185
 3 

d 

al 

onsidered an upper bound for sea salt while Cl- measurement is probably a lower bound. 

4 

are 

e 

d 

n with 

, 

nd sea 

s 

isibility condition would be higher using Na+ than using Cl- in the IMPROVE equation. 

alt 

ple recalculation of natural background 

onditions using Na+ instead of Cl-. 

 

IMPROVE analysis uses X-ray Fluorescence (XRF) spectroscopy for samples collected 

on the Teflon filter for elements, including Na. IMPROVE does not consider elemental

Na to be a reliable indicator for sea salt. Ion chromatography provides a more reliable

measure of Na+ ion, but IMPROVE does not routinely fund ion chromatography for 

cations. This is an economic decision in balancing costs for the 159 monitors in the

network. VISTAS funded non-routine ion chromatography analysis of Na+ on the 

IMPROVE filter samples for Cape Romain and several other VISTAS sites for the perio

Oct 2002 through Dec 2004. These Na+ data, corrected to account for Na+ associated 

with soils, provide an alternative estimate of sea salt values over a range of meteorologic

and seasonal conditions that is higher than the sea salt estimate based on Cl-. Because 

some of the measured Na+ may actually be associated with NO3 rather than Cl, Na+ is 

c

Figure 1 on the next page of this response illustrates light extinction for the 2000-200

baseline period under the Regional Haze Rule, calculated using the new IMPROVE 

equation. Light extinction from sea salt is largest on the days when extinction from 

sulfate and organic carbon is lowest. This suggests that sea salt values are highest when

winds are from the ocean rather than the mainland. Many of the days are classified as 

20% best visibility days. On days that aerosol loading of sulfate and organic carbon 

highest, sea salt is a very minor component of light extinction. Beginning in 2004, 

VISTAS has funded operation of a nephelometer at Cape Romain. The nephelometer 

measures light scattering by aerosols and gases in the atmosphere at ambient temperatur

and relative humidity. This direct measure of visibility correlates well with calculate

light extinction based on measured aerosol loading at the Cape Romain. This direct 

measure can be compared to calculated visibility using the new IMPROVE equatio

either Cl- or Na+ as the measure of sea salt. Because fine particle mass and light 

extinction at Cape Romain under current conditions are dominated by ammonium sulfate 

and organic carbon and because sea salt is a very minor component of total aerosol mass

it is not possible to demonstrate that one indicator of sea salt is a better than another13. 

The new IMPROVE equation uses Cl- as a measure of sea salt. If Na+ were to be used 

instead of Cl- to calculate sea salt mass, current visibility would be little changed because 

current visibility on the days defined by IMPROVE as being the worst visibility impaired

due to aerosol loadings are dominated by ammonium sulfate and organic carbon a

salt has little additional contribution. However, for 20% best days under current 

conditions or estimated natural conditions in the absence of anthropogenic sources of 

carbon and sulfate, sea salt becomes a larger percentage of total mass and the difference

in the two estimates of sea salt becomes more important. Thus the natural background 

v

Because the 20% worst days would need to be selected based on the revised sea s

values, it is not possible to provide a sim

c

13 Tombach, I. 2007. Evaluation of Alternative Methods for Estimating Sea Salt Concentrations at Cape 

Romain. Report to VISTAS, Feb 18 2007. 

Appendix J - 186
ROMA1

Baseline Extinction, New IMPROVE Algorithm

Figure 1. Speciation of all data collected at the Cape Romain site for 2000 to 2004. The 

red line indicates the threshold above which days are counted as 20% worst days for each 

year. 

20% W > 92

0

50

100

150

200

250

300

J-02F-02

M-02

A-02

M-02

J-02J-02

A-02

S-02

O-02

N-02D-02

Extinction (Mm -1)

20% W > 102

0

50

100

150

200

250

300

J-01

F-01

M-01

A-01

M-01

J-01

J-01

A-01S-01O-01N-01D-01

Extinction (Mm -1)

20% W > 133

0

50

100

150

200

250

300

J-00

F-00

M-00

A-00

M-00

J-00J-00

A-00S-00

O-00N-00

D-00

Extinction (Mm -1)

20% W > 96

0

50

100

150

200

250

300

J-03

F-03

M-03

A-03

M-03

J-03J-03

A-03S-03O-03N-03

D-03

Extinction (Mm -1)

20% W > 116

0

50

100

150

200

250

300

J-04

F-04

M-04

A-04

M-04

J-04

J-04

A-04

S-04

O-04

N-04D-04

Extinction (Mm -1)

Appendix J - 187
pe 

v. As the science is 

refined, the estimate of natural visibility condition can be refined. 

mmon Sense” Coastal Knowledge Appears to be 

d in 

ty is 

ts 

ore 

ght and this meteorological influence is incorporated in the IMPROVE equation. 

p 2007, fog 

. This measure does not address aerosol contribution to visibility 

impairment. 

y 

in 

ulatory 

basis for evaluating a state’s progress in improving visibility in the Class I areas. 

5)

bles 

 CAIR, CAMR, the NOX Sip call and other regulations and planned 

mission reductions. 

 improvements projected for 2018 are not as large 

y 

s 

 

Using the VISTAS Na+ measurements for IMPROVE samples for 2004 from Ca

Romain (average of 0.73 μg/m3, less than the 1.3 value offered in the SCPPA’s 

comments), natural background visibility might increase 1.0 to 1.5 d

4) SCPPA is concerned that “Co

Missing from the Equations 

The SCPPA’s comments that weather is not considered in the IMPROVE equation an

modeling are incorrect. The entire year of 2002 was modeled in the meteorological, 

emissions and air quality models, including periods of rain and fog. Relative humidi

used as a factor in the calculation of light extinction for sulfate, nitrate, and sea salt 

because relative humidity increases the efficiency of light scattering by these componen

that absorb water. At higher relative humidity the same particle mass will scatter m

li

Relative humidity is routinely measured at Cape Romain in conjunction with the 

nephelopmeter. Using relative humidity greater than 90% as an indicator when fog or rain

affected visibility, we can estimate that during the period Jan 2004 through Se

or rain likely affected visibility roughly 40% of the hours of operation of the 

nephelometer

The objective of the Regional Haze Rule is to mitigate man-made impairment of visibilit

on national parks and wilderness areas, thus the focus is on that component of visibility 

impairment that is caused by human emissions. EPA Guidance for Tracking Progress 

under the Regional Haze Rule14 defines the approach to be used to calculate visibility 

based on aerosol mass, extinction efficiency, and relative humidity. This is the reg

Planned Emission Reductions

Emissions summaries for 2002 and 2018 are provided in Appendix D.2.a. Several ta

summarize the emissions reductions from existing regulations including reductions 

expected as a result of

e

6) SCPPA is concerned that visibility

as projected emission reductions.

The air quality model is first run for 2002 using 2002 inventories and 2002 meteorolog

and model performance is demonstrated. Then the model is run using using the 2002 

meteorology with 2018 inventory to project the changes in air quality in 2018 due solely 

to changes in emissions (holding meteorology with all the seasonal variations the same as

2002). The change in emissions from 2002 to 2018 is reflected in changes in air quality 

for every day of the year. EPA guidance defines that the calculation of visibility change

14 EPA-454/B-03-004, September 2003 

Appendix J - 188
for 2018 will be based on the average of the changes for each of the 20% worst or 20% 

2 

sponse on all 20% worst visibility days is less than average SO2 

missions reductions (see Figure 2). These seasonal factors have been considered in the 

2. Modeled Changes in Light Extinction in response to 2018 emissions changes, 

r each component of PM2.5 mass, for the 20% Worst Visibility Days at Cape Romain in 

7)

best visibility days as defined by aerosol loadings in 2002. 

The conversion of SO2 to SO4 is temperature and oxidant dependent and is much more 

efficient during hot summer conditions than during the cooler winter months. Because 

several of the days determined by IMPROVE methods to be the 20% worst days in 200

are winter days, and because conversion of SO2 to SO4 is less efficient on cooler days, 

the average sulfate re

e

VISTAS analyses. 

Modeled Responses to 2018 Base G2a Emissions on 20% Haziest Days

Cape Romain, SC

-120

-100

-80

-60

-40

-20

0

20

Figure 

fo

2002. 

SCPPA is concerned that naturally occurring ammonia and sulfates are not 

considered. 

Ammonium sulfate is considered as part of natural background visibility in the EPA 

Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule15. 

Average natural concentrations of ammonium sulfate were estimated to be 0.23 μg/m3 

 

15 EPA-45A/B-03-005, September 2003. 

17 29 44 47 53 110 122 155 158 182 185 188 197 200 206 212 236 254 257 260 293 296 299 341 Avg

Delta Bext (1/Mm)

Julian Day

bCM

bSOIL

bEC

bOC

bNO3

bSO4

Modeled Responses to 2018 Base G2a Emissions on 20% Haziest Days

Cape Romain, SC

-120

-100

-80

-60

-40

-20

0

20

17 29 44 47 53 110 122 155 158 182 185 188 197 200 206 212 236 254 257 260 293 296 299 341 Avg

Delta Bext (1/Mm)

bCM

bSOIL

bEC

bOC

bNO3

bSO4

Julian Day

Appendix J - 189
with a range of 0.12 to 0.46 μg/m3. The GEOS-Chem global chemistry model16

estimated that annual average natural background concentrations of ammonium sulfate in

the eastern US were 0.11 μg/m3, very similar to that used in EPA’s original estimate. The

estimate for natural background ammonium sulfate on the 20% worst visibility days base

on the revised methods to calculate natural conditions using the new IMPROVE equatio

is0.29 μg/m3. These values can be compared to ambient concentrations of ammonium 

sulfate measured by IMPROVE at Cape Romain on the 20% worst visibility days in 20

that ranged from 4.4 to 17.8 μg/m3. Fin

d 

n 

02 

e and coarse soils and volcanoes are natural 

urces for sulfate, as is the ocean. None of these natural sources are significant 

8)

c 

re used to 

efine the frequency that air masses that arrived at Cape Romain traveled over specific 

9)

e 

ted 

 area dominate any natural 

sources of SO2 in the area. Reductions in SO2 emissions will result in air quality, 

10) ility 

l 

. 

arbon 

 to 

s 

g 

 

so

compared to current anthropogenic SO2 emissions. 

SCPPA is concerned that Back Trajectories Are Not Appropriate for Conducting 

Area of Influence Analysis.

The objective of the SO2 Area of Influence analysis was to understand which geographi

area was most likely to influence Cape Romain. Back trajectory analyses we

d

geographic areas. This analytical approach is appropriate for that purpose. 

SCPPA is concerned that a Cause-Effect Relationship between Ammonium Sulfate 

and Visibility Has Not Been Clearly Established.

South Carolina respectfully disagrees with the SCPPA. The air quality benefits that hav

resulted from SO2 emissions reductions to date have been well documented and were

discussed under item 2 above. There is always more to learn but it can not be dispu

that anthropogenic emissions of SO2 in the Cape Romain

visibility, and public health benefits for South Carolina. 

SCPPA is concerned that Sources of Organic Carbon and their Impact on Visib

Appear to be Incomplete.

Sources of organic carbon include natural vegetative emissions, vegetative detritus, 

prescribed fire, wild fire, land clearing, residential wood combustion, gasoline and diese

engines, industrial point sources, marine traffic, coal combustion, cooking and road dust

VISTAS is investing considerable effort to better understand sources of organic c

including special monitoring studies, improvements to the regional air quality model

better characterize secondary aerosol formation, and improvements in emissions 

inventories. VISTAS funded special sampling for carbon at 5 sites, including Cape 

Romain for April 2004 through May 2005. Chemical Mass Balance and Positive Matrix 

Factorization analyses are underway now to determine relative source contributions to 

measured organic carbon. Analyses of carbon 14 isotope in carbon samples indicate that 

modern sources of carbon (vegetative emissions, vegetative detritus, biomass burning, 

cooking) are more important than fossil sources (gasoline, diesel, coal, oil), accounting for 

60 to 80% of measured carbon throughout the year. Monitoring data in Figure 1 of thi

response indicate likely impacts from fires in spring and fall 2000, June 2001, sprin

rk, R.J., Jacob, D.J., Field, B.D., Yantosca, R.M., Chin, M. 2003. Natural and Transboundary Pollution 

ences on Sulfate-Nitrate-Ammonium Aerosols in the United States and Implications for Natural Visibility.

16 Pa

Influ 

J. Geophysical Research, 108, D12, 4355. 

Appendix J - 190
 8 

 

. 

utheast 

e 

11)

 as 

 procedures and quality assurance project plans17. 

ower, shelter, and road access are required to operate the monitor. The incremental 

contributions of road dust, vehicle exhaust, recreational boating and vegetative emissions 

from previous emissions reductions 

and the scientific data bases used to develop the State Implementation Plan have been well 

documented and reviewed. There are always opportunities to improve our understanding and 

strategies to improve air quality as we move forward toward the goal of no man made 

impairment to visibility by 2064. For this first implementation period the data and science 

presented is sufficient to justify the conclusions drawn. 

 

2002, and April 2004. It is likely that eight of the 100+ 20% worst days in 2000-2004 

were impacted by fire episodes. Fire may have been a factor on additional days. 

EPA guidance estimates annual average natural background conditions for organic carbon

as 1.4 μg/m3 with a range of 0.7 to 2.8 μg/m3. Using the new IMPROVE equation, the 

annual average for organic carbon would be 1.8 μg/m3 with a range of 0.8 to 3.6 μg/m3.

These estimates assume carbon from vegetative emissions, natural fires, and the ocean

There is still much to learn about source contributions to organic carbon in the so

and this will be one of the areas of focus for future regional haze analyses. The majority 

of 20% worst visibility in the 2000-2004 baseline period are dominated by SO4 and th

focus in this SIP on SO2 emissions is appropriate. 

 SCPPA is concerned about the reliability of data collected at Cape Romain

The Cape Romain IMPROVE monitor meets citing criteria for the IMPROVE network

described in the standard operating

P

in the vicinity of the Cape Romain monitor can be estimated in the future. As seen in the 

2000-2004 baseline data for Cape Romain in Figure 1, soil and coarse mass are minor 

contributors to light extinction. 

In summary, air quality benefits have been demonstrated 

17 http://vista.cira.colostate.edu/improve/Publications/publications.htm 

Appendix J - 191