# Appendix J Consultation Process

### 1. Introduction
The Southeast Regional Planning Organization, Visibility Improvement State and Tribal Association of the Southeast (VISTAS), iscomprised 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 havegreater 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 befound attached to this Appendix.
Neighboring states are still in the process of evaluating BART and reasonable progress.The Mid-Atlantic/Northeast Visibility Union (MANE-VU) states of New Jersey and New Hampshire sent letters to South Carolina inthe 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.

### 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 sourcesaffecting 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 VISTASStates consultation meeting with the MANE-VU RPO................................................................................................................51
Letter: 10/15/07, Assistant Secretary for Fishand 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 .......................................................................................................63Electronic 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.......................................................................................................................182Forest Southern Region 1720 PeachtreeRoad

### NW Selvice ' 4 Atlanta, Georgia30309



### Myra Reece 

# sc Department ofHealth and Environmental Control Bureau ofAir Quality 2600 Bull St. Columbia, SC 29201

## - 1797

Dear Ms. Reece: File Code: 

### 2580 Date: October 10, 2006 

# WaD

BUREAU OF 

## AIR 

## QUALITY

Over the past several years, our staffhas participated with members ofyour 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 ofyour Regional Haze StateImplementation Plan (SIP) is at hand, we want to direct our attention to a close collaboration directly with you and your staffto 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 facilitateto the extent possible a common message fi-omthe federal land managers 

### (FLM). We anticipatethat we will be ableto leverage the strengths fi-omeach ofthe FLMs to your advantage and to ours. Sincethe 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-omacross 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 pertinentto SIP preparation. Any comments or questions about these perspectives shouldbe 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 consultationon your SIP now and through the required 60- day comment period. Working with others on our staff, especiallyour National Haze Coordinator, Ann Mebane (307-587-4597, amebane("fs fed us), 

### and with the DOI, he will provide you with ourbest insights and recommendations.

As required in the 

### RHR, at your earliest convenience, please identifjrthe key point(@of contact
on your staffwith whom Bill may work on the SIP. Send all correspondenceto both Bill Jackson and Ann Mebane. We would prefer this electronicallyto the extent possible.

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

Caringfor the Land and Se&g Peopk Printedon RecydedPapa 

# fi

### Sincerely, 

## -

Enclosure

### Enclosure (1)



### The 

### followingperspectives are merely suggestions orrecomme~tions notdirection or requirements. lheyare deliberately verysimilar to thoseprepared by the Depurtment of Interior to contribute to a common

### sense of 

### purpose for improving haze in 

### all ClamI areas. We
are sending these perspectives to each state. In sorloing,we hope to facilitate inter-state coordination. At the same 

### time, we fully 

### acknowledgethe dscretionaflorkd in the 

### RHR for unique and

### creativesolutions by individualstates in writing plans that reduce haze.

Natural Conditionand 

### Uniform Rate These factors apply mainly to States that have Class 

### I areas. Other States that contributeto visibility impairment in Class

### I areas located in a different statemight consider including discussion and conclusions on these factorsin their individual plans.

The basic calculation ofbaseline, 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 ofthe methods used in the SIP. Calculations that include only portions of establishedmethods or utilize unique approaches will be 

### better understood if the rationale for these differencesis hlly explained in the SIP or its supporting documentation. We encourage statesto use calculations that are based on equations recommended by the IMPROVE steering committeeand that are consistent with recommended approachesfrom the pertinent RPO and the Environmental Protection Agency (EPA) region.



### Emission Inventories Given the complexities associated with modem comprehensiveemission inventories, spending some considerable effort in describinghow these inventorieswere developed 

### and used will be important. Emission descriptionswill be most informativeif they include an evolutionary discussionthat includes; an actual, base-year inventory 

### used to evaluate model performance; a typical, base-year inventory that representsthe five year, average state which establishes modeled visibility impacts; and various hture year, controlPed inventories that demonstrate fbturevisibility conditions. Consider adding kture year inventoriesthat 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 ofyour emission inventory includes the implementation of "Best Available Retrofit Technology" (BART) on a subset ofpre-Prevention of Significant Deterioration sources. BART source identification,elimination, 

### and level determinationwill 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.

### Area 

### of Influence The 

### area of influence of significant visibility-impairing sources is an important SIP element. We suggestthat that each state clearly identifj. and apportion by State, or other geographic means, the significant levels ofpollutants contributed toeach 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 ofpresenting this information in the fonn of transported mass by pollutant orthrough 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 Godsand 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 strategiesto meet these goals, form the basis ofthe 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 Statesto 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 ofprogress 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 ofprogress, our review will focus holistically on (1) whether strategies are applied equitably across 

### source 

### types,(2) ifboth 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 ofthe 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 ofprogress was made in the focus area, verses other less controllable factors.



### Wildland Fire Your state has considerable flexibility asit addresses all anthropogenic sources ofvisibility impairment, including fire. The

### RHR requires consideration of smoke management techniques for agricultural and forestry management practices in the development ofthe LTS part ofthe SIP. On a short-term basis, fire, both 

### natural and anthropogenic, 

### has the potential tocause significant visibility reduction in Class 

### I areas. If anthropogenic fire contributes to the index

### 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 SMPrequirements for minimizing visibility impairment in Class I 

### areas and classify the various types ofwildland 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 aretreated? 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 Statemay wish to develop strategies that
are independent from RPO or neighboring 

### areas.



### In this context, our review of "regional consistency" will have lessto 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 ofapportionment 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 aspart of an ongoing progress review at five year intervals. Given the uncertain hture ofany individual monitoring site, we suggest 

### that the SIP addressthe representativeness ofboth primary and alternative data sites for each class I area.
Consider not only the data necessary tomeasure 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 errorsthat may 

### be found in emission inventories or other technical bases ofthe 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. Consideringthese factors through adaptive management or continual review strategies may assist in avoiding these circumstances.

### Coordinationand Consultation The 1999 

### Regional 

### Haze Rule requires Statesto 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 letterto this attachment, a single Forest Service air specialisthas been assigned 

### to your state. He will facilitate the coordination of comments from multiple Forest ServiceFLMs ifthey exist in your state.1 

# United 

# States 

# Department 

# of the Interior

FISH

### AND WILDLIFESERVICE

National WildlifeRefuge System Branch ofAir Quality

IN

REPLYREFER 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, theU.S. Fish and Wildlife Service (FWS), National Park Service (NPS), and Forest Servicehave participated in regional planning efforts addressingways for States, and Tribes if they so choose, to protect and improve visibility in Class 

### I national parks and wildernesses through implementation ofthe Regional Haze Rule (RHR). Along with other stakeholders, we have had many opportunities to contributeto ongoing Regional Planning Organization 

### (RPO) development of policy guidance and technical information. As Statesbegin to develop their regional haze State implementation plans (SIPS)based on RPO 

### work, we are interested in working directly with your staffto 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 ascoordinate 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 ofthe 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 individualsnoted in the enclosure. Additional information regarding your SIP timelines would also be very helpful.

### 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 emphasisis 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 areasthroughout the United States, and we wouM like to use thisplanningprocess 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 asthe regianal haze SIPSare developed. Please don't hesitate to contact us 

### with questions. Sincerely,

SandraV. 

### 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

### Fire 

### Your State

### has considerable flexibility as it addresses all anthropogenic sources of visibility impairment, including fire. The RHR requires considerationof smoke managementtechniques for agricultural and forestry managementpractices in the development of the LTS part ofthe SIP. On a short-term basis, fire, both natural 

### and anthropogenic, has the potential to cause significant visibilityreduction in Class I 

### arm. If anthropogenic fire contributes to the indexused 

### to track long-term, reasonable pqgess in a Class I area, the visibility SIP should identifyhow 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 contributeto visibility impairment,the SIP should contain a comprehensive emissions inventory for all fire emissions and a statementrelating 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 Stateswith a SMP, the SIP 

### should identifj its type, i.e., a basic smoke management program 

### or an enhanced smoke managementplan, and ifthe plan has been certified consistentwith EPA's Interim & 

### Quality Policy on Wildlandand Prescribed Fire. 

### Itwould also be useful to know specific SMPrequirementsfor minimizingvisibility impairmentin Class 

### I areas and classificationofthe various types of wildland fire (wildfire, prescribed fire, and wildland fire 

### use fire) as either natural or anthropogenic. Any differencesregarding the regulation of agricultural burning versus prescribed burning by 

### private, State or Federd land managers should also be identified with discussion ofthe basis for any differences provided. Regional Consistency 

### The Regional Planning Organizations (RPOs) have been working toward regiondlyconsistent approaches to address visibility impairmentthroughout the SIP development process. There may be circumstanceswhen different methods were used or impairment 

### assessments reached different conclusions. We understand that each State knows what emission control methods or air 

### quality management strategieswork best for its areas Each Statemay 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 Statehas 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 difficultto evaluate ifneighboring SIPs (or portions of SIPs) are released for review at different times. It 

### is ourhope that thorough inter-State consultation processes will lead to consistent descriptions of apportionmentand 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 Each SIP must identify monitoring data aspart ofthe 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 ofboth primary 

### and alternativedata sites.

We encourage Statesto not onIy consider the need for these data to measureprogress, but also how the plan accounts for and reconcilesboth unexpected and reasonably foreseeable emissions growth, changes to the geographic distributionofemissions, and substantive errors that may be found in emission inventories or other technical bases of the SIPs. These factors, as well as other unanticipatedcircumstances, may adversely affect your State's ability to achieve the emissions reductionsprojected by the SIP. Considering these factors through adaptivemanagement or routine review processesmay 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 51.308(i)). Specifically, the Federal Land Manager 

### (FLM) for the Department ofthe Interior (DOT)

### is the Assistant Secretary for Fish and Wildlife and Parks. 

### However, assistancein the development and technical review of Regional Haze SIPs will 

### be conductedby the FWS Branch ofAir Quality 

### and NPS Air Resources Division.

To help facilitateconsultation with the FLMs, each Bureau has developed a review strategy that includes a singlepoint of contact for all interaction with 

### us. For your State, primary DO1 contactnames are:
Tim Allen 

### U.S. Fish & 

### Wildlife Service Mailing Address: 7333 W. Jefferson, Suite 375 Lakewood, CO 80235 Phone: 303-9 14-3802 Fax: 303-969-5444 Email: Tim Allen@,fws.POV

### Regional Haze State Implementation Plan Coordinatiy Fish & 

### Wildlife Serviceand National Park Semiice-' August 1,2006

This document is designed to provide you general 

### in&ghtsabout U.S. Fish and Wildlife Service (FWS) and National Park Service (NPS) hnterests with respect to upcoming Regional Haze Rule (RHR) StateIrnplemen~&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 Statesthat have Class 

### I areas. Other States that contribute to visibilityimpairmentia 

### Class 

### I areas should consider including discussion and conclusions on these factors in their individual plans.

As you know, the basic calculationofbaseline, natural condition, and uniform rate builds the fod~ation for the entireRHR SIPprocess. Considerablediscussionand debate at the scieilce and policy level has occurredregarding appropriate methods to be used. As a consequence, several equationsthat include varying parameters or multipliers are available. Because these calculations can have a significant effect on the resulting progress goal, it iscritical that the Stateprovide a detailed description of the methods used in 

### its SIP. 

### If calculations include only portions ofestablished methods or utilize previously undocumented or unsupported approaches,morejustification should be included in the SIP or its supporting documentation. We encourage States to consider calculations that are based on equationsrecommended by the IMPROVE steering committeeand that are consistentwith 

### recommended approaches fiom the appropriate RPO andEnvironmental Protection Agency (EPA) region.



### Emission Inventories Given the complexities associated with 

### modern, comprehensiveemission inventories, considerableeffort should be placed on describinghow these inventorieswere developed and used. We would like to see emission descriptions demonstrate an evolution that includes: an actual, base-year inventoryused to evaluate model performance; a typical, base-year inventory that representsthe 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, orgraphics) 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 andjustification.

Onepart ofyour emission inventory includes the implementationof "Best Available Retrofit Technology" (BART) on a 

### subset ofpre-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

### three basic BART phases and a thorough description ofthe

### RHR prescribed factor analysis (if applicable). Discussions should clearly identify whether 

### BART control levels apply to individual or grouped source categories.

Area ofInfluence 

### 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 apportionedby State, or other geographic means, to encompass emission sources that contribute significant levels ofpollutants 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 presentingthis information in the form oftransported 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 overtime.
Reasonable Progress Goals and 

### Long Term Strategy 

### As you also know, establishingreasonable progress goals for Class I areas in your State andlor acknowledging reasonableprogress goals for Class I areas in other States that are affected by emissionsfrom your State, as

### well as 

### defining associated emissions strategies to meet these goals, form the basis ofthe SIPprocess under the RHR.

In developingthe Long Term Strategy(LTS)required by the RHR, your State has broad flexibility when determining reasonable pgressgoals and associated emissions. As noted earlier, the RHR includes a requirement forStates to assess a uniform rate of progress and comparethat rate to the reasonable progress goals set by those Stateswith Class I 

### areas. We believe that this uniform rate ofprogress 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 degreetowhich the LTS is supportedby 

### RPO technical work and at the level of consistency among the contributing States. For Class I areas where the State is setting a 2018 

### reasonable progress goal of equal or less impairment compared to the uniform rate ofprogress, it would assist our review to present informationon 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 ofprogress, States should considerpresenting additional information on 

### a component basis. Components could consist of emission source categories asbefore, but also include contributionsfrom individualpolhtants 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.

### Bruce 

### Polkowsky National Park Service
MailingAddress: OvernightPackages: 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 appreciatecommunicationsin electronic form 

### as much as 

### possible. This will allowus 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. Resourceand information examples include progress reports, discipline experts, orimplementation advice. Although the 

### RHR places
a strong emphasis on individual discretion in developingthese plans, the NPS 

### and FWS would be happy to provide more specific suggestionsor information, in a form most useful to you, upon request.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

### 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 SIPSbefore 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, NPSTable 

### 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/m3or > 

### 2% Sulfate Contribution MANE-

### W member 

### 4 of 5 techniques (QD, Remsad, Calpuff 1 &2) MANE-VU member
> 

### 0.1 ug/m3or > 

### 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/m3or > 

### 2% Sulfate Contribution
> 

### 0.1 ug/m3or > 

### 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 1Northeast 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.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 ofthe public andthe 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 StateImplementation 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 VisibilityImprovement 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.

SOUTHC A R O L I N A D E P A R T M E N T OFHEALTH AND ENVIRONMENTAL CONTROL 2600Bull Street Columbia,SC29201 Phone:(803) 898-3432 www.scdhec.govRegional 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

### The State of New Hampshire 

## DEPARTMENT OF 

## ENVIRONMENTAL SERVJE~ CEIVED

-a 

### . 

# &?TO? ;:EAL 

# - 5 EiJYi2i??$.i:lr~lT:,1_ CD 

# ES

Thomas 

### S. Burack, Commissioner 

## 2007 APR 

## 12 

## AH10:

QfFiCE 0; 

### ilj: I:I~MH~SS~OKER 

### April 4,2007 CHIEF 

### OF STAFF 

### CLERK OF 

### SCOHEC BOARD 

### C. Earl Hunter Commissioner SC Dept. ofHealth and Env. Control 2600 Bull Street Columbia, SC 29201

Dear CommissionerHunter:

As you are aware, New Hampshireis 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 ofMt. Washington, the highest point 

### in the NortheasternUnited 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 airpollution. Fortunatelyfor those who visit this region and for those who live and work there, the Regional Hazerule requires that these areas and 154 others nationwide gradually improve visibility, with a goal of achievingnatural conditionsby 2064. While this ultimate god is' decades away, we begin today by taking reasonable actions andby

### parbering in consultation with states and Canadian provinces, as needed, to begin planning to take the first stepstoward meeting this 

### goal. I 

### write today because wehave identified your state
orprovince as one that needs to be part of our collective solution to regional haze 

### in New Hampshire. Accordingto the Clean Air Act, all U.S. states must submit StateImplementation Plans (SIPS)by December 2007 for regional h'aze, regardless ofwhether they arehome 

### to a Class 

### I area. Under the Act's section 169A (including regulations at 40 CFR 5

### 1.300), the regional haze SIP 

### must demonstratethat reasonableprogress 

### willbe made at nearby Class I 

### areas at 10-year intervals, beginning in 

### 2018. 

### The regulations of40 CFR 51.308(d)(l)(iv) specify that states with Class 

### I areas should develop reasonable progress goals for their Class I 

### areas and associatedmeasures to meet those goals, in consultation with anyjurisdiction that may reasonably cause or contributeto 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 PresidentialRange

### -Dry River Class I 

### areas, we have limited our requests for consultationsto 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

### Northeast -

### Visibility Union 

### (MANE-VU)to consult with us. Because we have asked you tojoin us in consultation does not necessarily implythat 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. Byjoining 

### 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 arepresentative 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 JeffUnderhill ofmy staff at 603-271-1370 

### (or email: 

### junderhill@des.state.nh.us).

Sincerely Yours,

Thomas S. Burack Commissioner

cc: Robert Scott, NHDES Air ResourcesDivision JefEeyUnderhill,NHDES Air ResourcesDivision Anna Garcia, OTC Arthu Marin, NESCAUM SusanWeirman,MARAMABOARD: 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.

SOUTHCAROLINA DEPARTMENT OFHEALTH AND ENVIRONMENTAL CONTROL 2600Bull Street Columbia, SC 29201 Phone:(803)898-3432 www.scdhecgov

### 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, 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

### - 1797

Re: Four Factor Analysis for Regional Haze 4244 International Parkway Suite 120 Atlanta Georgia 30354 4041363-7000 Fax:4041363-7100 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 :nus1submiiro EPw a Sbace In:piern~.i~~a~i~n pian (SiF)~hal t-siaklisr~\~> reasonable progress towards achievjng natural visibility ~r~nditiom. In order 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 2018. Based on this

,7,,, t-.. -:I:!: .-- :-Ti,..-.-:.- -.-A -+-;mh5cr:z-ot?+-c h2~/.2 k.cty: :dq!?r5<dh\.E!)g zp ~IIUI~X~, a ~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.

# 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,! 

### - 1Th. 

### 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 BEWINGCO - 

### 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

# 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 ALUMINTJMCOMPANY OF AMERICA 

### - SOUTH PLAN - 

### UNIT 16 ALUkllN liM cOMl'k~\l 

### k Oi. F.lvlEK,CA 

### - SUL, iki 

### PLXru 

### - Uiu 1i i 'I 

### BOWATER NEWSPRINT & 

### DIRECTORY - 

### CALHOUN - 

### UNIT 

### 015 E. I. DU PONT DE NEMOURS AND COMPANY - 

### UNIT 0002 EASTMAN CHEMICAL COMPANY 

### - UNIT 021520 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.. 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, VISTASBOARD: 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 ofthe 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 ofNatural Resources Environmental ProtectionDivision, Air Protection Branch 4244 InternationalParkway, 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

SOUTHCAROLINA DEPARTMENT OFHEALTH ANDENVIRONMENTAL CONTROL 26q0BullStreet Columbia,SC29201 Phone:(803) 898-3432 www.scdhec.gov

### 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.

### 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: RobertJ. Brown, Jr., Director, Division of Air Planning, Development and Outreach, SCDHEC Stacey Gardner, Manager, Regulation Development Section, SCDHEC Pat Brewer, VISTAS Technical AdvisorVISTAS State Consultation Meeting Federal Land Managers and Environmental Protection Agency Asheville, North Carolina June 12, 2007

Attendees/Af filiation
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 bethe 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• 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 betweenstates, FLM, and EPA of revised reasonable progress guidance

• This first SIP for regional haze will be a learning experience. States canuse 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 benef it from reducing SO2 from electric utilities or industrial point sources and littlebenefit 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 intotwo 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• 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 0 3 22 NO W.Virginia don't know 9 47 NO Florida 1 maybe 1 31 NO Kentucky 1 2 15 NO Mississippi 0 2 17 NO N. Carolina 0 14 21 NO S. Carolina 3* 3 13 NO Virginia 1 or 2 3 25 NO Georgia 1 or 2 4 13 NO Tennessee Controlled Subject Eligible Complete 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 0 3 22 NO W.Virginia don't know 9 47 NO Florida 1 maybe 1 31 NO Kentucky 1 2 15 NO Mississippi 0 2 17 NO N. Carolina 0 14 21 NO S. Carolina 3* 3 13 NO Virginia 1 or 2 3 25 NO Georgia 1 or 2 4 13 NO Tennessee Controlled Subject Eligible Complete STATEIssues 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. Statescan 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 withKY 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 inmonitoring data may also be considered but may be difficult to interpret due tointer-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.• 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 theyget a copy of the SIPs 60 days prior to the public hearing.

• If states are not going to meet the Decem ber 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 indifferent 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?Infollow 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 in2000-2004, 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.Discussion of Revised Regional Haze Guidance

• EPA cautioned that states need to becaref ul 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 touse 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 eff ectiveness. It is not intended to beused 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.

### 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 ofHealth & 

### 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 ChristopherRecchia 

### 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

### 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 lgthis 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.

### The third is a Statementthat 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

### North Carolina Department of Environmentand 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 40CFR 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. Thepurpose of this letter is to discuss our reasonable progress evaluations forNorth 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,NC27604 Phone:919-715-7670 1Fax: 919-715-74761Internet:ww.ncair.orq

An Equal OpportunitylAffirmaliveAction Employer- 50% RecycledllO% Post Consumer PaperMyra 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 specificpurpose 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 implicationsthat 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 assessmentsbelow must be considered only within the limited regulatory framework of the Regional Haze Rule.
NCDAQ Process on Reasonable Progress Assessment



### The following summarizesthe 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 addressingthe 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 CAEdo 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 assessmentperiod (between baseline and 2018).Myra Reece August 2,2007 Page 3 of 4

Step4: 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 Step4 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 economicburden 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 assessmentindicated there are no North Carolinaunits 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 contribute0.2% 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 50,000tons 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 reasonableprogress for this first planning period of the Regional Haze State Implementation Plans (SIPS). It should be noted that Progress Energy, Duke Energy and other facilitiesin 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 SIPdevelopment.


### 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) indicatesthat 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 theMyra Reece August 2,2007 Page 4 of4



### 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 ofthe 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 12,2007in advance of the public hearings to be held during the week ofNovember 12, 2007, or 2) prior to the end of the public comment period which is scheduled to close sometime during the week ofNovember 26,2007. Should your staffhave any questions on this letter or on North Carolina's regional haze state implementation plan development, please contact Sheila Holman ofmy staff at (919) 715- 0971. 

### I look forward to continuing to work with you both directly and through VISTAS. Sincerely, 

# >dqdUL -4 B. 

### Keith Overc sh, P.E. 

### - - 

### Director

Attachments

Cc: John Hornback, SESARMIMetro4Director Kay Prince, EPA Region 4I 

### 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.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 SO2and NOxin the eastern United States. When fully implemented, CAIR will reduce SO2emissions 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 CAIRMr. Overcash November 9, 2007 Page 2
and CAMR-required SO2controls 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-NOXburners) 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 AdvisorMANE-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 causeor 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 Statesagreed to pursue the adoption and implementation of emission management strategies to assure reasonable progress toward preventing any future and remedying any existing im pairment 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 st rategies, as appropriate and necessary:

• Timely implementation of BART requirements; and• 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 eachState 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 thatVISTAS 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 providea 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 inthe southeastern US and SO2 emissions controls would be the most effective measures to improve visibility• VISTAS Base G2 inventory relies on IPM v2.1.9 EGU projections for CAIR updated with controls provided by the sources insummer 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 qualitymodeling results indicate visibility improvements on 20% worst days in 2018 greaterthan 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 dayswhen SO2 emission reductions are as large as in the summer months but sulfate formation is lower and so the benefit of SO2 emissions reductionsis 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 havethe 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 toindividual sources.

• VISTAS states will continuedialog with MANE-Vu states.During the afternoon session Statesshared 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.

# b

United States Department 

## of the Interior 

## w-j
OFFICE OFTHESECRETARY Wash~ngton, DC 20240 

# w

TAKE PRIDE' 

# ,ocv 0 

## 9 2007 INAMERICA

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)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, andprovide 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) 914-3802.

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 orjustifications 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."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 A01Analysis 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 seethis added to the SIP narrative.

### 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 2l), 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.

### 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 A01for 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.

### 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.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)

### 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 fireBOARD: 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 73-73 

### 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 on the draft SIP.

011

### October 15,2007, the Departmentreceived 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 describethe particular subject matter. , 3



### Thc 

### Department appreciates the depth and specificity ofthe U.S. Fish & 

### Wildlife Service in irs 

### review of the State's SIP. The attached document serves to specifically address the
conunents 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 2600BullStreet Columbia,SC29201 Phone: (803) 898-3432 wwwscdhecgov

### 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 freeto 

### contactme at 

### (803) 898-2230or masonmr@dhec.sc.szov. Sincerely,,

Dil

### ision ofAir.Planning, Development & 

### Outreach Burcau of 

### Air Quality Socith 

### CarolinaDepartment of

### Health and Environmentiu ~onnoi

Renee Shealy, Assistant Bureau Chief, SCDHEC Stacey Gardner, Manager, Regulation Development Section, SCDHEC I'at Brewer, VISTAS TechnicalAdvisor- 3 - U.S. Fish and Wildlife Service Comments Regarding South Carolina Draft Regional Haze Rule State Implementation Plan
Pursuant to the requirements codified infederal 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 tomake 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 receiveabbreviated 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 inwhich 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 ForestryCommission (e.g., attending the BlueSkyRAINS- 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 cont ribute 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 notedthat Santee Cooper is some 425 miles from Swanquater, and therefore by definition, outsideits Area of Influence. In addition, Santee Cooper: Jeffries and SCE&G: Canadysare 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 areasare determined differently based on a myriad of characteristics particular to an area.

Comment 6 – POM and EC: These comments have been addressed inthe 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.- 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: Thiscomment 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 inCape 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 todevelop a system to track this data for use in the next planning stage.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 9Comments 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 1have not been fully addressed by the state andforthe 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.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.. . 

### 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 39161 -39162, 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?

### Under this section, we suggest the language in paragraph 1 on page 11be 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 SIPSmust 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 ofthis 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 ofthe 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 ofthe 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 SIP8. 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 SIPNarrative 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 SOzcontrol 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). Therequirements 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 VegetativeDebris 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 SMPwithout 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 

### 3Determine if

### CAIRis sufficient for reasonablepronress 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.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 ofthese 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 ofthe 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.

### 20. Section 

### 7.8.3.3, page 

### 88: This section contains a brief discussion ofthe 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 ofthe 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 101.1 

### krn. This is very close to the 100km 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 ofthe 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." Nojustification 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

### 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 2018 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 ispresented 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

### 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 ofthese 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 ofthe meteorological files (i.e., hardcopies ofthe 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 ReviewThis 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.

### 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 ofthis 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/correlationof 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.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 Stateto 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 Statesthat 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.

### 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 ofthese 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 additionaljustification 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 ofAirPollutant Emission Factors(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 ofthe sources relying on these documents. Also, the comments in Attachment ofthis 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 NO2data, 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 NOxconcentration 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.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 1-4tothe April 30,2007 letter with final modeling results not submitted in appendix. See a similar comment for the DAK Cooper River facility.

### ATTACHMENT 

### 3
Q: The BART Model Plant Exemption in 40 CFR Part 51,Appendix Y, Section 111 (70 

## FR 39162-39163, July 6,2005) does not address PM; it only considers emissions of SO2and NOx. The BART Guidelines state that the Model Plant Exemption may be used if a BART-eligible source's emissions of SO2or 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 SO2or 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 ajustification for including PM is provided. Thejustification should address how the light extinction resulting from the PM emissions compares with the light extinction resulting fiom emissions of SO2andlor 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 topotential 

### emissions--(this is not specified explicitly in the BART Guidelines).

The Georgia Department ofNatural Resources developed ajustification 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.

## 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

### 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 ofthe 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 affectedby 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) "Ifthe 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 A01identified 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 ofthe 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.

### 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 ofthe Regional Haze SIP will have the correct values.

3. In 

### Appendix 

### J there is a reference to a letter submitted on 8/6/2007by Keith B. Overcash (State ofNorth 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 10and 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 ifthe 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 ofthe Class I areas in the southern Appalachians from West Virginia to northern Georgia. If all parties are agreeableto 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.BOARD: Paul C. Aught~y 111 Chairman Edwin H.Coop:r, 111 Vice Chairman Steven G. Kisner Secretary 

# DHEC 

# ~!!l!!l~

PROMOTEPROTECT PROSPER

C.EdHunter, 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

Decermber 1'7,2007

Ms. Marisue Ilillard Forest Supervisor USDA Forest Service Post Office Box 2750 Ashe\iIle, NC. 28802

Dear Ms. Hi1liard:

South C'nrolina has prepared a draft SIP to addressvisibility 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 StareRegister in October2007, solicitingcommentson 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 servesto specifically addresseach ofthe commentsreceived.

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 ISdue to EPA by December 17,2007. We hope that the changes made to the final SIPpackage
serve tc> address all the comments/concernsthat 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 Serviceto 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) 898-2230or masonmr(ir>,dhec.sc.tzov.

Sincerely ,

Robert J



### . Bro~n, .f!r., Director Division ofAir Planning, Development & Outreach Bureau of Air Quality South Carolina DepartmentofHealth 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 2600Bull Street Columbia, SC 29201 Phone:(803)898-3432 www.scdhecgov2 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 sectionsof 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 visibilityimpairment...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) inorder 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 neededto 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 im pact 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 thisconcern. 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 sour ces 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-Slickrock3 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 necessaryduring 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 todetail 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 withyour finding that wildland fires emissions are not a significant contributor to visibility im pairment at the Class I areas and further4 emission reduction techniques from prescribedfires 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 thisfinding 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 includedas 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 thisdocument 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 Underst anding as a commitment to its ongoing relationship. In addition, it should be noted that the De partment 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 o pportunity to establish a joint technical committee to include the aforementioned statesand FLMs. As such, this has been noted in the final SIP submittal (Chapter 11).

### 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 HazeAir 

### 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 remediationofmanrnade airpollution,which contributesto thevisible 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 regulationsto address visibility impairmentthat is "reasonably attributable" to one or a small groupof sources located across a broad geographic area (referred to asregional 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 31, 

### 1997, the EPA published proposed amendments to the 1980 regulations to set forth a program to addressregional haze [62 FR 4 11381. 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," (alsoreferredto 

### asthe 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. TheEPA isrequiring all statesto revise their State Implementation Plans (SIPs) to reduce emissions of sulfurdioxide (SO*),oxidesof nitrogen (NO,), and particulatematter--especially fine particulate matter (PM;? 5)--all ofwhich contributeto 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 ofavisibility-impairing airpollutant that wasput 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.

### Page Two Regional Haze State Implementation Plan November 9,2007

The EPA has established a 

### schedule for states to submit their SIPS.South Carolinamust 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, November26,2007.

In a telephone discussionon Wednesday, November 7,2007, Ms. Nacosta Ward recommendedthat the Departmentprovide an extensionof the public commentperiod in ordertoencourage stakeholder involvement in the SIPamendmentprocess. 

### In accordancewith Ms. Ward's request, the Department has, via electronic mailing and the Department's website, advised the public of an extension ofthe comment period through 

### December 12,2007. Accordingly, the Department requests that EPA acknowledgethe 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 SIPnarrative and most ofthe supporting appendicesto the EPA on August 2 1,2007.) Enclosed with this letter is an electronic copy ofthe proposed S@ amendment, including all associated appendices. The Department appreciates the assistanceprovided by you and your staffregarding the formulation ofthisplan. Shouldyou or your staffhave any questionsor comments concerningthis SIPrevision, please contact Ms. Maeve S.R. Mason ofthe Bureau of Air Quality at 803-898-2230.
Sincerely,

Robert 

### J. Brown, Jr., Director Air Planning, Development and OutreachDivision 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 CarolinaDecember 18, 2007
Ms. Nacosta C. Ward, Environmental Scientist U.S. Environmental Protection Agency, Region 4 Air, Pesticides & ToxicsManagement 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 issuesincluding 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

### 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 ofAir Quality South CarolinaDepartment of Health and Environmental Control



### cc: Renee Shealy, Assistant Bureau Chief, SCDHEC Stacey Gardner, Manager, Regulation Development Section, 

### SCDHEC I'at Brewer, VISTAS Technical AdvisorMs. 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 beprovided 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 inAppendix 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 inChapter 8 of the SIP narrative.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 satisfiessources’ 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 SCDHEC 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.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 Modelingdated July 18, 2006, in many cased the speciation of particulate matter required for BARTanalysis 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 isthe 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 NOXand SO2emissions 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 NarrativeMs. 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 inSC SIP) includes a detailed model performance evaluation for the VISTAS region. In Appendix B of the Technical Support Document, additional graphicsand 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 linegraphs 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 SO4on four summer days with high (>8 μg/m3) measured SO4 peaks and significantly over predicted SO4on several consecutive fall days with low (<4 μg/m3) SO4values. NO3model performance is poor; over predicting NO3values in the cold months (1 st and 4thquarters) and under predicting NO3in the warm months (2ndand 3rd quarters). The NO3under prediction is not of concern because observed values are generally less than 0.5 and so NO3does not contribute significantly to visibility impairment on these days. The NO3over prediction in winter months is of greater concern because the relative reduction factors for NO3may be affected by model performance. Over prediction of winter timeammonia values may be the reason for the over prediction. The model captures temporaltrends for organic carbon and elemental carbon, including winter peaks, although some summer time peaks were over predicted. Soil was generally over predicted while coarsemass 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 coarsemass 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.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 Figure1-1 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 (PM2.5and 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 beenaddressed. Comment 2 questionsthe 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) itis 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 to10 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.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 irizdpi-otrcti~g thehcnirh 

### 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 29 116-1028

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 exemptingthe 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 documentationto 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 CarolinaDepartment 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.govBOARD: 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 andpmtecttng the heaith ofthepublic 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, RegulationDevelopment Section, SCDHEC Pat Brewer, VISTAS Technical Advisor Permit File 1040-0003

SOUTH (;IZROI,INX DEPXKTMFNT OFHEAI>TH AND ENYIRONMENTAL CONTROL 2600Bull Street Columbia,SC29201 Phone:(803) 898-3432 www.scdhec.govBOARD: 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~ tile horlth ofthepublzr 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 1306Amoco 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 demonstrationis 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, 2600Bull Street Columbia,SC29201 Phone: (803) 898-3432 www.scdhec.govBOARD: 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 exemptingthe 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 documentationto 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 ofAir Quality South Carolina Department ofHealth 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

SOUTHCAROLINA DEPARTMENT OFHEA1,TH AND ENVIRONMENTAL CONTROL

-- ---- 2600Bull Street Columbia,SC29201 Phone:(803) 898-3432 www.scdhec.govBOARD: 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 ofthepub/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 documentationto 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 Departmentof Health and Environmental Control

cc: Robert J. Brown, Jr., Director, Division ofAir 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 OFH E A L T H A N D ENVIRONMENTAL C:ONTROI, 2600Bull Street * Columbia,SC29201 Phone:(803) 898-3432 www.scdhec.govBOARD: 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-,rotectzngthe herllth of'thepublic 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 includedocumentation 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 OFHEALTH AND ENVIKONMEN'TAI, CONTROL 2600Bull Street Columbia,SC 29201 Phone:(803)898-3432 www.scdhec.govBOARD: Paul C. Aughrry, I11 Chairman
Edwin H. Cooper, 111 Vice Chairman
Sreven G. Kisner Secrerary 

# DHEC 

# urn

PROMO1 k 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 andpt.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 (1140-0002). 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 TechnicalAdvisor Permit File 1140-0002

SOI'TH C:AROI.lIV.A DEPARTMENT OF HEALTH AN11 EIVl'IRONMEN r.II>CONTROI, 2600Bull Street Columbia,SC29201 Phone:(803) 898-3432 www.scdhec.govBOARD: 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 andprotecting the liealtl~ ojthe 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. (Idl~ec.sc.~~o~. 

### Sincerely,

Myra C. Reece, Chief Bureau ofAir Quality South CarolinaDepartment 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 TechnicalAdvisor Permit File 1380-0003

SOUTH CARO121NADEPARTMENT OF HEALTH AND EN\'IRONMENTiII, CONTROL 2600Bull Street Columbia,SC29201 Phone:(803)898-3432 www.scdhec.govBOARD: Paul C. Aughtry, 11I 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 andprotecting the health ofthepri 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 furtherBART 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 Departmentof Health and Environmental Control

cc: Robert J. Brown, Jr., Director, Division ofAir Planning, Development and Outreach, SCDHEC Stacey Gardner, Manager, RegulationDevelopment Section, SCDHEC Pat Brewer, VISTAS TechnicalAdvisor Permit File 2060-0345

SOUTHCAROLINA DEPARTMENT OFHEALTH AND ENVIKONMENTiiL CONTROL 2600Bull Street Columbia,SC29201 Phone:(803)898-3432 www.scdhec.govBOARD: 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 exemptingthe 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 includedocumentationto 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 1140-0004

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, 2600Bull Street Columbia,SC29201 Phone:(803) 898-3432 www.scdhecgovBOARD: 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 thepubllc and the enl~rronment



### December 7,2007

Mr. Duane Mumrnert MeadWestvaco Corporation,Inc. Post Office Box 118005 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 ofAir Quality South CarolinaDepartment ofHealth and Environmental Control

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

### Planning, Development and Outreach, SCDHEC Stacey Gardner, Manager, RegulationDevelopment Section, SCDHEC Pat Brewer, VISTAS Technical Advisor Permit File 0560-0008

SOUTHCAROI-INA DEPLAR1'MENTOFHEALTH AND EN\71RONh.IENTALCONTROI, 2600Bull Street Columbia,SC 29201 Phone:(803)898-3432 www.scdhec.govBOARD: 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 andprotecting the health oj'zhrp~rblic- iznd tile en~~ir01~rn~~i2t



### December 7,2007

Mr. Ben Williams Milliken & 

### Company Post Office Box 817 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 furtherBART 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 documentationto 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 CarolinaDepartment of Health and Environmental Control

cc: Robert J. Brown, Jr., Director, Division ofAir 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 

## 1BOARD: Paul C. Aughrry, I11 Chairman Edwin H. Cooper, 111 Vice Chairman
Sreven G. Kisnrr Secretary PROMOTE PROIECT PROSPtK 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 ($'thepublic- 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 greatervisibility impairment in any Class I Federal area, thus exempting the source(s)from furtherBART 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 ofAir Planning, Development and Outreach, SCDHEC Stacey Gardner, Manager, Regulation Development Section, SCDHEC Pat Brewer, VISTAS Technical Advisor Permit File 0200-0031

SOUTH (:AROI.INA DEPARTMENT OFHEAII,THAND ENVIRONMENTrlI, CONTROL 2600BullStreet Columbia,SC29201 Phone:(803) 898-3432 www.scdhec.govBOARD: 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 oftl~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 StreetExtension Charleston, SC 29405

Re: Regional Haze Exemptionfrom 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

SOUTHC:ARO121NA DEPARTMENT OF HEALTH -AND ENVIRONMENTAI. CONTROL 2600Bull Street Columbia,SC29201 Phone: (803)898-3432 www.scdhec.govBOARD: 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~ ofthepnblrr 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 ofAir 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 (1340-0003), Jefferies (0420-0003), Winyah (1140-0005)

SOUTHCAKOI.INA DEPARTMENT OF HEALTH AND EN\TIRONMENTXI. CONTROL 2600Bull Street Columbia,SC29201 Phone:(803) 898-3432 www.scdhec.govBOARD: 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 ofthepu6licnizd 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 documentationto 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 0820-0013

SOu TH CAROLINA DEP-ARTMEIVT OF HEALTH AND ENVIRONMENTAI. CONTROL

--- ----- 2600Bull Street Columbia,SC29201 Phone:(803)898-3432 www.scdhec.govBOARI): 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 (1900-0013), 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)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: 804-698-5134


### 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-omthe 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-omVISTAS, and the VISTAS representatives were accessible and

1 SEVIC's comments were based upon a pre-hearingdraft version ofthe SIP dated August 10, 2007, beforea subsequent version ofthe 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 ofthe referenced subject matter in the later version.

ATLANTAHONG KONG LONDON NEW YORK NEWARK 

## - NORFOLK 

## - RALEIGH RICHMOND 

## - SHANGHAI 

## - TYSONS CORNER 

## - VIRGINIA BEACH 

# - WASE-IINGTON, D.C.

### 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 SIPSto 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,

### 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 achievedby 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

EnclosureComments 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 SIPmust lay the appropriate groundwork for those SIPS which follow. Although as discussed herein, SCDHEC is able tojustifi 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.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"dsentence: "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 2018 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 

### notrequire 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

### notrequired 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 determinationofcontributors 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 ofthis 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 ofprogress."
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 ofprojected 2018 emissions. According to the discussion in the first paragraph of this section, emission sensitivity runs were initially performed using "the initial 2018 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 2018 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 iscorrect, 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 ofthose 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 2018 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 2018 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 2018. 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 2018.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 2018 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 A01were 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".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 ofreasonable 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 ofthe 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 15years-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 1BART-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.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 ofthe 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 Underthe Regional Haze Program, § 5.0,p. 1 (Nov. 28,2005).context of the congressional goal, i.e., visibility improvement to natural background levels in class I areas. Clearly, future regional haze SIPSfor 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 ofthis 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 Underthe Regional Haze Program, 5-1 (June 1,2007) (hereinafter "Reasonable Progress Guidance").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, 1980Proposed Regulations for Visibility Protection for Federal Class IAreas, 172 (Oct. 1980).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 ofutility installations ofretrofit SO2 controls projected through 2015, availabilities ofthose 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.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 ofthe "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.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 ofthe 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 ultimateconclusion, 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 ofprogress, 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 thatjustification must be based upon appropriate considerations of visibility impairment at Cape Romain in 2018 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 ofthis 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.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, ofthe 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 ofthose 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 ofEGUs subject to CAIR do not make any significant contribution to visibility impairment in Cape Romain? Is DHEC attempting tomake 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 ofthe 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 ofthe 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 ofindividual 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."

4thline: After the word "reducing", add the words "those precursors of'.

7thline: Replace the words "The most important sources" with "Sources with the greatest emissions".
10, 3rd 

## 7 6thline: After the word "areas" at the beginning of the line, replace the word "or" with the words "consisting of '.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



### . . .".

4thline: 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".Replace the word "indicates" with the word "is"

Table 2.3-1: Inclusion ofthe 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".

4thline: 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"

4thline: 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".

5thline: Correct the spelling of "IMPROVE"
22, lSt7 1

# " line: Change the word "has" to "makes"
24, lst

### 7 6thline: 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 ofprogress (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."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 ofthe 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.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."7thline: 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 4thline: 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 2018,



### . . ".

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"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."

4thline: The words "cause or" are unnecessary.

2nd line: Change the word "improved" to "will improve"

3rdline: "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 ofthe 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"?

3rdand 4thlines: 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 ofbeing "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.89, Last 

### 1 2"dline: Change the words "were given exemption status" to "were found to be exempt fiomBART".

90-93 Section 7.9: As SCDHEC acknowledges, the expected visibility improvement expected in 2018 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.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 im pairment with the express intent that by 2064, the visibility in all Class I areas willbe 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 dedicatedto 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 commentssubmitted 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.

### Should you have any further questions concerning South Carolina's regional haze SIP development, please feel fieeto 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, RegulationDevelopment Section, SCDHEC I'at 

### Brewer, VISTAS TechnicalAdvisorAttachment 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 SO2AOI 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 usedthe 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 SO2emission would result in a larger benefit than reducing NOXand 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 samefashion 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 receivedon 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

34 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.%. 

## SaTH GZROLINA 

### CHAMBER 

# v COMMERCE December 11.2007 BUREAU OF All1 UUALI1-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 8031779-6043Ms. Maeve S R Mason December 11.2007 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 SIPrevisions, 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-relationshipsbetween 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 SIPcall, 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 activeMs. Maeve S R Mason December 11,2007 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 appropriatelydone 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 clarificationbe 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 inconsistenciesin 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 conditionsMs. Maeve S R Mason December 11,2007 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 14.1Ms. Maeve S R Mason December 11,2007 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-OccurringAmmonia 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,

### Ms. Maeve S R Mason December 11,2007 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 TrajectoriesAre 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-EffectRelationship 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 80to 90% of the carbon is of modern origin (i.e., non fossil, hence not from petroleum and coal). Attributing organic carbon to man### Ms. Maeve 

### S R Mason December 11,2007 Page 7

made emissions and not reflecting this in the Uniform Further Progress (glidepath) calculations is inaccurate and misleading and must be corrected. The Chamberrecommendation 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 submittedto 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 measurementsused for RHR implementationneed to be extremely accuratelpreciseif 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 considerabletraffic from large yachts and commercial vessels being transportedup 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 particulatesthat 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.Ms. Maeve S R Mason December 

### 11,2007 Page 8



### Conclusions The Chamber complements SCDHEC on the extensive effort put forward to support VISTAS and the other stakeholdergroups 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 responsibilityof the state agency, but rather the responsibility of EPA, the FLMs and the organizationscreated 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 CommerceBOARD: 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 ofthepublic 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 1201 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 OFHEALTH A N D E N V I R O N M E N T A L CONTROL 2600Bull Street Columbia, SC29201 Phone:(803) 898-3432 www.scdhec.govMr. 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 AdvisorResponses 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 timeallowed 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 scientif ic 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 articles 1

, 2

, 3

,4

, 5

, 6were 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 currentvisibility conditions, track changes in visibility, and determine causes of haze in national parks and wilderness areas. IMPROVE

1Brewer, 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 2Tombach, I. and Brewer, P. 2005. Natural Background Visibility and Regional Haze Goals in the Southeastern United States. J. Air & Waste Management Association55:1600-1620. 3Morris, 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. 4Morris, 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. 5Tesche, 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. 6Odman, 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,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. IMPROVEhas rigorous monitoring standard operating procedures and dataquality 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 CleanAir Act Amendments have resulted in significant reductions in sulfate deposition8and 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 citesections of the Narrative at discuss how sea salt was addressed.

how

n of both natural background and current conditions in the new PROVE equation 12

.

f NaCl. 9

, 10. As discussed in Appendix B, Conceptual Description, IMPROVE data demonstrates visibility improvement at 8 sites in the VISTAS region, including CapeRomain, over the period 1995to 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 Rule 11defines current and natural background visibility conditions should becalculated 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

7IMPROVE Standard Operating Procedures and IMPROVE Aerosol Quality Assurance Project Plan http://vista.cira.colostate.edu/improve/Publications/publications.htm 8Dennis, 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. 9Malm, 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. 11EPA-454/B-03-004, September 2003 12Pitchford, 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.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 islargest 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 inthe 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. Thusthe 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

13Tombach, I. 2007. Evaluation of Alternative Methods for Estimating Sea Salt Concentrations at Cape Romain. Report to VISTAS, Feb 18 2007.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-02 F-02 M-02 A - 02 M- 0 2 J- 02 J-02 A- 0 2 S-02 O-02 N-02 D - 02Extinction (Mm-1) 20% W > 102

0 50 100 150 200 250 300

J

- 0 1 F-01 M- 0 1 A-01 M-01 J- 0 1 J-01 A- 01 S-0 1 O-01 N - 01 D-01Extinction (Mm-1) 20% W > 133

0 50 100 150 200 250 300

J-00 F- 0 0 M - 0 0 A - 0 0 M-00 J-00 J- 0 0 A- 00 S- 00 O-00 N -00 D -00Extinction (Mm-1)

20% W > 96

0 50 100 150 200 250 300

J-03 F-03 M-03 A- 0 3 M- 0 3 J-03 J-03 A-0 3 S- 0 3 O-03 N - 0 3 D-0 3Extinction (Mm-1)

20% W > 116

0 50 100 150 200 250 300

J

- 0 4 F-04 M- 0 4 A - 0 4 M- 04 J- 0 4 J-04 A- 04 S- 04 O-04 N - 04 D-04Extinction (Mm-1)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 meteorologicalinfluence is incorporatedin 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 NOXSip call and other regulations and planned mission reductions.

yimprovements 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 anindicator 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 Rule 14defines 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

14EPA-454/B-03-004, September 2003for 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 VisibilityConditions Under the Regional Haze Rule 15

. Average natural concentrations of ammonium sulfate were estimated to be 0.23 μg/m3

15EPA-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 AvgDelta 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 AvgDelta Bext (1/Mm) bCM bSOIL bEC bOC bNO3 bSO4

Julian Daywith a range of 0.12 to 0.46μg/m3. The GEOS-Chem global chemistry model 16 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. Noneof 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. Reductionsin 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 tobetter understand sourcesof 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. 16Pa Influ J. Geophysical Research, 108, D12, 4355.8 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 improveour 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 eightof 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

17http://vista.cira.colostate.edu/improve/Publications/publications.htm

### 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 Alh 

### iiWLlPl

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.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 ofthese 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 ofthe lack of massive emission reductions within a short period. The emission reductions that will occur as a result of CAR,CAMR, NOxSIP 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 ofhours 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 SCDHEC 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-ativeefort.

### 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.

### 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 ofpage 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 isproven, 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 ofthe 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 ofthe 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 ofthe 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 eflortMs. 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.

### Ms. Maeve S. R. Mason December 12,2007 Page 6



### subjective assumptions, do a poor job of evaluating point sourceplumes. 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 ofnaturallyoccurring 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% ofthe 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

### Ms. Maeve S. R. Mason December 12,2007 Page 7

site was subjected to a review ofmonitoring 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 ofthe 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 ofpine 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. SCPPAbelieves 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 ofthe data must be the paramount consideration given the dollar magnitude ofregulatory decisions that may result from the use ofthe 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 effortMs. 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 139or electronically at dam20@meadwestvaco.com.

Sincerely,

Duane Mummert, P. E. Chair, SC Pulp and Paper Association

cc: SCPPA Members

Eizvironmentalconcern with a cooperative effort.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 andprotecting 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 118005 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.

SOUTHC A R O L I N A D E P A R T M E N T OF HEALTH AND ENVIRONMENTAL CONTROL 2600Bull Street Columbia,SC29201 Phone:(803) 898-3432 www.scdhec.govMr. 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 

# Mp&

Robert 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 AdvisorResponses 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 encouragedand 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 articles 1

, 2

, 3

,4

, 5

, 6were 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 currentvisibility conditions, track changes in visibility, and determine causes of haze in national parks and wilderness areas. IMPROVE

1Brewer, 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 2Tombach, I. and Brewer, P. 2005. Natural Background Visibility and Regional Haze Goals in the Southeastern United States. J. Air & Waste Management Association55:1600-1620. 3Morris, 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. 4Morris, 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. 5Tesche, 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. 6Odman, 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,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. IMPROVEhas rigorous monitoring standard operating procedures and dataquality standards7. The SCPPA’s statement that SC has relied on new and inadequately tested methodologies is incorrect.

e

nitrate deposition and ozone.
naturally occurringsea salt at Cape Romain has not been

her

e comments then citesections of the Narrative at discuss how sea salt was addressed.

how

n of both natural background and current conditions in the new PROVE equation 12

.

f NaCl. 2) SCPPA incorrectly states that there have been no previous massive reductions in pollutants emissions that could be usedto 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 deposition8and 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 CapeRomain, over the period 1995to 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 Rule 11defines current and natural background visibility conditions should becalculated 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

7IMPROVE Standard Operating Procedures and IMPROVE Aerosol Quality Assurance Project Plan http://vista.cira.colostate.edu/improve/Publications/publications.htm 8Dennis, 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. 9Malm, 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. 11EPA-454/B-03-004, September 2003 12Pitchford, 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.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 islargest 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 inthe 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. Thusthe 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

13Tombach, I. 2007. Evaluation of Alternative Methods for Estimating Sea Salt Concentrations at Cape Romain. Report to VISTAS, Feb 18 2007.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-02 F-02 M-02 A - 02 M- 0 2 J- 02 J-02 A- 0 2 S-02 O-02 N-02 D - 02Extinction (Mm-1) 20% W > 102

0 50 100 150 200 250 300

J

- 0 1 F-01 M- 0 1 A-01 M-01 J- 0 1 J-01 A- 01 S-0 1 O-01 N - 01 D-01Extinction (Mm-1) 20% W > 133

0 50 100 150 200 250 300

J-00 F- 0 0 M - 0 0 A - 0 0 M-00 J-00 J- 0 0 A- 00 S- 00 O-00 N -00 D -00Extinction (Mm-1)

20% W > 96

0 50 100 150 200 250 300

J-03 F-03 M-03 A- 0 3 M- 0 3 J-03 J-03 A-0 3 S- 0 3 O-03 N - 0 3 D-0 3Extinction (Mm-1)

20% W > 116

0 50 100 150 200 250 300

J

- 0 4 F-04 M- 0 4 A - 0 4 M- 04 J- 0 4 J-04 A- 04 S- 04 O-04 N - 04 D-04Extinction (Mm-1)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 meteorologicalinfluence is incorporatedin 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 NOXSip 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 anindicator 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 Rule 14defines 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

14EPA-454/B-03-004, September 2003for 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 VisibilityConditions Under the Regional Haze Rule 15

. Average natural concentrations of ammonium sulfate were estimated to be 0.23 μg/m3

15EPA-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 AvgDelta 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 AvgDelta Bext (1/Mm) bCM bSOIL bEC bOC bNO3 bSO4

Julian Daywith a range of 0.12 to 0.46μg/m3. The GEOS-Chem global chemistry model 16 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. Noneof 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 todate have been well documented and were discussed under item 2 above. There is alwaysmore 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 OrganicCarbon 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 tobetter 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. 16Pa Influ J. Geophysical Research, 108, D12, 4355.8 . utheast

e

11)
as procedures and quality assurance project plans 17

. 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 improveour 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 eightof 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

17http://vista.cira.colostate.edu/improve/Publications/publications.htm