# Regional Haze State Implementation Plan Periodic Report

South Carolina Class I Federal Areas

Prepared by South Carolina Department of He alth and Environmental Control Bureau of Air Quality

December 28, 2012SC SIPR: Regional Haze Periodic Report (December 2012) 2 EXECUTIVE SUMMARY

The Clean Air Act (CAA) mandates requirements to protect visibility, es pecially in Class I Federal areas. In 1999, the US Environmental Pr otection Agency (EPA) finalized the Regional Haze Rule (RHR) (64 FR 35714). The rule calls for state, tribal, and federal agencies to work together to improve visibility in 156 national parks and wilderness areas, including the 21 Class I
Wilderness areas.

States are required to develop and implement air quality protection plans (State Implementation Plans, or SIPs) to reduce the pollution that caus es visibility impairment. These plans establish goals and emission reduction strategies based on trends from various sources including area source emissions, mobile source emissions (bot h on-road and non-road emissions), biogenic emissions, and wildfire and agriculture emissions.

In developing its SIP (submitted to EPA on December 17, 2007), South Carolina (SC) prepared a long-term strategy and examined the possible app lication of Best Availa ble Retrofit Technology (BART) in order to establish reasonable progress goals (RPGs) for Cape Romain. Given a final iteration of the emissions inventory known as BaseG4 was made available in 2008 (the result of which led to slight change in the calculation of the RPG (see Table 12)), the Department requests that EPA acknowledge an update to the State’s RPGs as a revision to the SC Regional Haze SIP. Regardless of this small change, the predicted reductions in visibility impairment were/are expected to result from implementation of existing and planned emission controls. This document is intended to address the requireme nts of 40 CFR 51.308(g) re quiring periodic reports evaluating progress towards the RPGs.

Ammonium sulfate is the largest contributor to visibility impairment at Cape Romain and reduction of sulfur dioxide (SO 2 ) emissions is the most effec tive means of reducing ammonium sulfate. As such, the majority of the focus with regard to existing and planned emission controls pertains to the largest sources of SO 2 emissions. These sources consist of electric utility steam generating units (EGUs). Other smaller industrial sources were identified in the initial SC Regional Haze SIP submittal, but these sources were not required to add additional BART
controls.

Many of the EGUs within South Carolina have co mmitted to and have installed controls through a number of mechanisms, including the Clean Air Interstate Rule (CAIR) and its successor the Cross State Air Pollution Rule (CSAPR), st ate programs, and state and federal consent agreements. Reductions associated with many of these mechanisms were used to estimate the 2018 visibility improvements at the Class I areas. However, since the development of the Best and Final emissions inventory for the SC Regi onal Haze SIP submittal, additional regulations and actions have been imposed on this source se ctor. These additional mandates will help ensure that RPGs are attained on or before 2018. Moreover, as recently as summer 2012, several large EGUs have announced plans to either shut down sources or curtail emissions by converting to natural gas; leading to even mo re significant reductions in SO 2 emissions. See Tables 10 and 11 for more source specific information.SC SIPR: Regional Haze Periodic Report (December 2012) 3 It is for these reasons that th e Department of Health and Envi ronmental Control (DHEC) submits a negative declaration to EPA specifying that it s Regional Haze SIP is sufficient in meeting the requirements outlined in the RHR. Furthermore, no additional controls are necessary based on this first South Carolina five-year progress report.SC SIPR: Regional Haze Periodic Report (December 2012) 4 Table of Contents

Introduction................................................................................................................... .................. 7
Final Rule Requirements for Progress Reports............................................................................... 8
40 CFR 51.308(g): Progress Towards RPG.................................................................................... 8
40 CFR 51.308(g)(1): Status of Measures in SIP ......................................................................... 11

1. Federal Programs ............................................................................................................... 12

1.1 2007 Heavy-Duty Highway Rule (40 CFR Part 86, Subpart P) ..................................... 12

1.2 Tier 2 Vehicle and Gasoline Sulfur Program (40 CFR Part 80, Subpart H; 40 CFR Part 85; 40 CFR Part 86) ................................................................................................... 12

1.3 Nonroad Diesel Emissions Program (40 CFR Part 89) ................................................... 12

1.4 Maximum Achievable Control Technol ogy (MACT) Programs (40 CFR Part 63) ..... 13

1.5 Federal Consent Agreements ............................................................................................. 15

2. EGU Control Strategies ..................................................................................................... 17

2.1 North Carolina Clean Smokestacks Act ........................................................................... 17

2.2 Georgia Multi-Pollutant Control for El ectric Utility Steam Generating Units ............ 17

2.3 Maryland Healthy Air Act (HAA) .................................................................................... 17

2.4 Clean Air Interstate Rule and Cross State Air Pollution Rule ...................................... 18

2.5 Utility Federal Consent Orders ......................................................................................... 19

2.6 Specific EGU Estimates and Reductions .......................................................................... 19

2.7 New EGU Control Strategies ............................................................................................. 19
2.7.1 Mercury and Air Toxics Rule......................................................................................... 20

2.7.2 2010 SO 2 National Ambient Air Quality Standard (NAAQS)....................................... 20
2.7.3 Tennessee Valley Authority Federal Consent Agreement ............................................. 20

3. Review of BART Determinations ..................................................................................... 23

3.1 South Carolina .................................................................................................................... 23

3.2 North Carolina .................................................................................................................... 24

3.3 Georgia

............................................................................................................................... . 24

4.0 Reasonable Progress Determinations ............................................................................... 26

4.1 Emission Control Measures Not Included in the Best and Final Inventory Effort ..... 26

4.2 North American Emission Control Area .......................................................................... 26

4.3 Residual Risk Requirements ............................................................................................. 27

4.4 Control Technique Guidelines ........................................................................................... 27
40 CFR 51.308(g)(2): Summary of Reductions Achieved ........................................................... 28

5. Overall SO 2 Emission Reductions .................................................................................... 28

5.1 EGU SO 2 Emission Reductions and Utilization ............................................................... 28

5.2 Additional EGU SO 2 Emission Reductions ...................................................................... 31

5.3 Unit Specific Point Source Reductions ............................................................................. 33SC SIPR: Regional Haze Periodic Report (December 2012) 5 40 CFR 51.308(g)(3): Assessment of Visibility Conditions......................................................... 36

6. Reasonable Progress Goals ............................................................................................... 36

6.1 Visibility Conditions ........................................................................................................... 37
40 CFR 51.308(g)(4): Emissions Tracking by Source Category.................................................. 42
40 CFR 51.308(g)(5): Changes to Anthropogenic Emissions ...................................................... 43

7. Measured Progress ............................................................................................................. 43

40 CFR 51.308(g)(6): Assessment of Elements to Meeting RPG ................................................ 46
40 CFR 51.308(g)(7): Assessment of Monitoring Strategies ....................................................... 47
40 CFR 51.308(h): Recommendations for 5 Year Progress Report ............................................. 49

8. Conclusions ......................................................................................................................... 49

List of Tables and Figures

F IGURE 0-1: C LASS I F EDERAL A REAS AND THEIR C ORRESPONDING A REA OF I NFLUENCE .............. 9

T ABLE 1: S OUTH C AROLINA E MISSION U NITS A FFECTING C LASS I F EDERAL A REAS IN G EORGIA 10

T ABLE 2: S OUTH C AROLINA E MISSION U NITS A FFECTING C LASS I F EDERAL A REAS IN N ORTH C AROLINA .............................................................................................................................. 11

T ABLE 3: MACT S OURCE C ATEGORIES WITH C OMPLIANCE D ATES ON OR AFTER 2002 ................ 13

T ABLE 4: ICI B OILER MACT R EDUCTIONS C OMPARED TO THE 2009 AND 2018 VISTAS

I NVENTORY ............................................................................................................................ 15

T ABLE 5: C OMPARISON OF CAIR & CSAPR SO 2 E MISSION LIMITS VS

. 2011 A CTUAL E MISSIONS 18

T ABLE 6: SC C OAL F IRED P OWER P LANTS : E XISTING AND F UTURE E XPECTED C ONTROLS AND
E MISSION R EDUCTION S TRATEGIES ....................................................................................... 21

F IGURE 2: S UBJECT

- TO -BART F ACILITIES AND P ROXIMITY TO C APE R OMAIN W ILDERNESS A REA

............................................................................................................................... ...... 23

T ABLE 7: S OUTH C AROLINA BART D ETERMINATIONS .................................................................. 24

T ABLE 8: CTG S P ROMULGATED IN 2006, 2007, AND 2008 ............................................................ 28

F IGURE 3: S OUTH C AROLINA A CID R AIN P ROGRAM U NIT E MISSIONS AND H EAT I NPUT D ATA ..... 29

F IGURE 4: VISTAS A CID R AIN P ROGRAM U NIT E MISSIONS AND H EAT I NPUT D ATA .................... 30

T ABLE 9: C OMPARISON OF A CID R AIN P ROGRAM D ATA FOR 2002, 2009, 2010, AND 2011........... 31

F IGURE 5: S OUTH C AROLINA SO 2 E MISSION R EDUCTIONS ............................................................ 32

F IGURE 6: SCE&G N ETWORK SO 2 E MISSION R EDUCTIONS .......................................................... 33

T ABLE 10: S UMMARY OF S OUTH C AROLINA EGU SO 2 C ONTROLS BETWEEN 2007 AND 2011....... 34

T ABLE 11: U NIT S PECIFIC R EDUCTIONS N OT I NCLUDED IN THE 2018 B EST AND F INAL
I NVENTORY ............................................................................................................................ 35

T ABLE 12: R EASONABLE P ROGRESS G OALS FOR SC ...................................................................... 36

F IGURE 7: R ATE OF P ROGRESS G LIDEPATH FOR 20% B EST D AYS AT C APE R OMAIN

, SC .............. 38

F IGURE 8: R ATE OF P ROGRESS G LIDEPATH FOR 20% W ORST D AYS AT C APE R OMAIN

, SC ........... 39

F IGURE 9: R ATE OF P ROGRESS G LIDEPATH FOR 20% W ORST D AYS AT C APE R OMAIN

, SC ........... 40

F IGURE 10: R ATE OF P ROGRESS G LIDEPATH FOR 20% B EST D AYS AT C APE R OMAIN

, SC ............ 41

T ABLE 13: S OUTH C AROLINA 2018 B ASE G4 E MISSIONS I NVENTORY BY S OURCE S ECTOR ........... 42

T ABLE 14: S OUTH C AROLINA 2007 E MISSIONS I NVENTORY BY S OURCE S ECTOR .......................... 43

T ABLE 15: S OUTH C AROLINA 2002 A CTUAL E MISSIONS I NVENTORY BY S OURCE S ECTOR ........... 43SC SIPR: Regional Haze Periodic Report (December 2012) 6 F IGURE 11: 5-Y EAR E XTINCTION FOR THE M AJOR C OMPONENTS OF R EGIONAL H AZE AT C APE
R OMAIN

............................................................................................................................... .. 44

F IGURE 12: M AJOR C OMPONENT C ONTRIBUTION ON 20 P ERCENT B EST D AYS .............................. 45

F IGURE 13: M AJOR C OMPONENT C ONTRIBUTION ON 20 W ORST D AYS ......................................... 46

Appendices

Appendix A: Back Trajectory Analysis of Beta Extinction Appendix B: Point Source SO 2 Emissions Reductions Appendix C: Notice of Gene ral Public Interest Appendix D: Written Comments Appendix E: Copy of Legal AuthoritySC SIPR: Regional Haze Periodic Report (December 2012) 7 

### Regional Haze Five-Year Progre ss Report Review Requirements

Introduction

The Clean Air Act (CAA) mandates requirements to protect visibility, es pecially in Class I Federal areas. In 1999, the US Environmental Pr otection Agency (EPA) finalized the Regional Haze Rule (RHR) (64 FR 35714). The rule calls for state, tribal, and federal agencies to work together to improve visibility in 156 national parks and wilderness areas, including the 21 Class I
Wilderness areas.

States are required to develop and implement air quality protection plans (State Implementation Plans, or SIPs) to reduce the pollution that caus es visibility impairment. These plans establish goals and emission reduction strategies based on trends from various sources including area source emissions, mobile source emissions (bot h on-road and non-road emissions), biogenic emissions, and wildfire and agriculture emissions.

These SIPs were developed to re duce visibility impairment with the express intent that by 2064, the visibility in the Class I areas will be returned to natural conditions. Five multi-state regional planning organizations (RPO s) are currently working together to develop the technical basis for these SIPs. The products of the regional planning organizations have been used to establish monitoring strategies for evaluating visibility conditions, baselines, and trends, and to develop long-term (10 to 15 years) strategies for maki ng “reasonable progress” toward eliminating all manmade visibility impairment from mandatory Cl ass I areas. With the help of the Visibility Improvement - State and Tribal A ssociation of the Sout heast (VISTAS) RPO, South Carolina has developed a SIP to address visibi lity impairment in the State’s Class I Federal Area--the Cape Romain Wilderness Area (Cape Romain)--located on the eastern coast of South Carolina.

In developing its SIP (submitted to EPA on December 17, 2007, 1 herein referred to as the SC Regional Haze SIP), South Caroli na prepared a long-term strategy and examined the possible application of Best Available Retrofit Technology (BART) in order to establish reasonable progress goals (RPGs) for Cape Romain. As provid ed in its SIP, for the 20 percent worst days, South Carolina has adopted a RPG of a 3.8 deciview (dv) reduction in vi sibility impairment by 2018, which is consistent with the uniform rate of progress needed to achieve a natural background condition of 12.1 dv by 2064. Likewise, S outh Carolina has also adopted a RPG for the 20 percent best days that w ould result in a 1.4 dv reduction in visibility impairment. Given a final iteration of the emissions inventory known as BaseG4 was made available in 2008,
calculation of the RPG for the 20 percent best days was revised to 1.5 dv (see Table 12)). The Department requests that EPA acknowledge an upda te to the State’s RPGs as a revision to the SC Regional Haze SIP. The aforementioned pred icted reductions in visibility impairment were/are expected to result from implementation of existing and planned emission controls that
will be discussed in further detail.

1 SC DHEC, South Carolina Regional Haze State Implementation Plan for South Carolina Class I Federal Areas

, December 17, 2007 (Available at http://www.scdhec.gov/environment/baq/docs/regs/other/SIPR%2020071221.pdf

, last visited October 25, 2012).SC SIPR: Regional Haze Periodic Report (December 2012) 8 This document is intended to address the requirements of 40 CFR 51.308(g) requiring periodic reports evaluating progress towards the RPGs esta blished for each mandatory Class I area. To be sure, “The EPA believes that a requirement for regular SIP revisions will result in a more effective program over time and provide a focu s for demonstrating ongoing progress and making mid-course corrections in emission strategies” (62 FR 41151). In accordance with the requirements listed in Section 51.308(g) of the RHR, South Carolina in its original SIP committed to submitting a report on reasonable progress to EPA every five years following the
initial submittal of the SIP. The document fulfills this requirement and is in the form of a SIP revision. This reasonable progress report evaluates the progress made towards the RPG for Cape Romain as well as in each mandatory Class I Federal area located outside South Carolina that may be affected by emissions from South Carolina sources

.



### Final Rule Requirements for Progress Reports

In its final RHR, published as final July 1, 1999, (64 FR 35714), the EPA included two main requirements for comprehensive periodic plan revisions (section 51.308(f )) and progress reviews (section 51.308(g)). Section 51.308(f) requires the st ates to submit a comprehensive SIP revision in 2018 and every 10 years thereafte r. Section 51.308(g) requires pr ogress reports for each Class
I area in the state in the form of SIP revisions ev ery 5 years. This SIP revision meets the latter of the two requirements discussed above.

40 CFR 51.308(g): Progress Towards RPG

40 CFR 51.308(g) requires that “a report to the Administrator... evaluating progress towards the reasonable progress goals for each mandatory Class I Federal area located within the State and in each mandatory Class I Federal area located outside the state which may be affected by emissions from w ithin the State.”

Figure 1 illustrates the Class I Fe deral area located within South Carolina along with its area of influence (AOI) as well as the Cl ass I Federal areas located outside of the State (either in North Carolina or Georgia) who based upon their AOI, may be affected by emissions from within
South Carolina. For more information on the State’s geographic AOI, please see Appendix H (4.0: Reasonable Progress Evaluati on) of the SC Regional Haze SIP.Figure 0-1: Class I Federal Areas and their Corresponding Area of Influence

Section 51.308(d)(1) of the final RHR requires th at states establish RPGs for each Class I
Federal Area within the state or shown to contribute to visibility within neighboring states. In establishing RPGs, the EPA provided analytical requirements for setting these goals (known as the four factors) which include: the cost of co mpliance, the time necessary for compliance, the energy and non-air quality environmental impacts of compliance, and the remaining useful life of any existing source subject to such requirements.

During the original SC Regional Haze SIP de velopment process, both Georgia and North Carolina submitted letters to South Carolina requ esting that the Department consider additional
controls for several in-state sources. These requests focused on those facilities that Georgia believed were likely to contribute equal to or greater than 0.5 percent to the total visibility impairment at its Class I Federal Areas, and No rth Carolina believed were likely to contribute more than one percent to the total visibility impairment at its Class I Federal Areas.

SC SIPR: Regional Haze Periodic Report (December 2012) 9 Tables 1 and 2, define those point sources in South Carolina for which emission were found to potentially affect visibility at either Georgia or North Caro lina’s Class I Federal Are a(s), respectively. Of these emission units in Table 1, all but three are electric utility steam generating units (EGUs) that were found to be subject to the Clean Air Interstate Rule (CAIR) (see Appendix M of the SC Regional Haze SIP). The three remaining sources: Giant, Holcim, and Meadwestvaco (now Kapstone) performed a four f actor analysis, the resu lts of which indicatedthat none of the evaluated options were econom ically feasible (see A ppendix N of the SC Regional Haze SIP).

Table 1: South Carolina Emission Units A ffec ting Class I Federal Areas in Georgia

Past/Projected Emissions (tpy) South Carolina Facility Sources Relative
Contribution

2002 2018 Distance (km)
to GA Class 1
Areas Existing
Controls

Santee Cooper –
Jeffries 003 0.010 11,315 6,761 WOLF - 245 Electrostatic Precipitators (ESPs) (1969/75) Santee Cooper –
Jeffries 004 0.010 11,789 6,609 WOLF - 242 ESPs (1970/75)

Santee Cooper –
Cross 002 0.005 10,260 3,380 WOLF – 244 ESP (1984)
Selective Catalytic Reduction (SCR) (1995)
Flue Gas
Desulfurization (FGD) (1995) Santee Cooper –
Cross 03 0.006 0 3,835 WOLF – 244 ESP 2006
SCR 2006
FGD 2006 (at startup)

Giant Cement 005 0.007 2,825 3,893 WOLF – 223 Fabric Filters Holcim – Holly Hill 002 0.006 496 492 WOLF - 235 ESP
Fabric Filters 2,315 2,706 OKEF – 297 MeadWestvaco (Kapstone) 006

0.008 2,315 2,706 WOLF - 213 ESP (1984 + 1977)

0.007 6,214 5,203 OKEF – 295 SCE&G Canadys 001

0.017 6,214 5,203 WOLF – 201 ESP

0.007 6,585 5,144 OKEF – 295 SCE&G Canadys 002

0.016 6,585 5,144 WOLF - 201 ESP

Note: Sourc es in Bold are subject to CAIR. Tables 6, 10, and 11 provide information on the
status of the controls for t hose sources subject to CAIR.

Table 2 defines the emission units at the point so urces in South Carolina that were found to contribute to visibility at the North Carolina Class I Federal Ar eas. Of these sources, all were EGUs found to be subject to CAIR and are thus exempt from any further review during this, the first progress report period (see Appendix M of the SC Regional Haze SIP).

SC SIPR: Regional Haze Periodic Report (December 2012) 10Table 2: South Carolina Emission Units Affect ing Class I Federal Ar eas in North Carolina

Note: Sourc es in Bold are subject to CAIR. Tables 6, 10, and 11 provide information on the
status of the controls for t hose sources subject to CAIR. Past/Projected Emissions (tpy) South Carolina Facility Sources Relative
Contribution

2002 2018 Distance (km)
to Class 1

Areas Existing Controls

0.033 2,386 4,347 SHRO - 93 Duke Energy – Lee 001

0.012 2,386 4,347 JOKI - 165 ESP

0.031 2,643 4,140 SHRO - 93 Duke Energy – Lee 002

0.011 2,643 4,140 JOKI - 165 ESP

0.055 4,384 7,274 SHRO - 93 Duke Energy – Lee 003

0.020 4,384 7,274 JOKI - 165 ESP

Santee Cooper –
Jeffries 003 0.011 11,315 6,761 SWAN - 425 ESPs (1969/75)

Santee Cooper –
Jeffries 004 0.011 11,789 6,609 SWAN - 425 ESPs (1970/75)

40 CFR 51.308(g)(1): S tatus of Measures in SIP

40 CFR 51.308(g)(1), requires “A de scription of the status of im plementation of all measures included in the implementation plan for achiev ing reasonable progress goals for Class I areas
both within and outside the State.”

This summary provides a status of the emission reduction measures that were included in the Regional Haze Best and Final inventory and RPG modeling effort. This summary includes
discussions of benefits associated with each m easure. Such benefits are quantified wherever possible. In instances where implementation of a measure did not occur in a timely manner, information is provided on the source category a nd its relative impact on the overall future year
emissions inventories.

The paragraphs below also contain information on emissions strategies that were not included in the Best and Final inventory and modeling effort. At the time of the Best and Final inventory development process, these measures were not fully documented or had not yet been published in final form, and therefore the benefits of thes e measures were not included in future year
inventories. Emission reductions from these measur es will help ensure that each Class I area meets or exceeds the visibility progress goal set in the SC Regional Haze SIP.

SC SIPR: Regional Haze Periodic Report (December 2012) 11SC SIPR: Regional Haze Periodic Report (December 2012) 12 1. Federal Programs

The em ission reductions associated with the federa l programs that are described by the following paragraphs were included in the VISTAS future year emissions estimates. Descriptions contain qualitative assessments of emissions reductions associated with each program, and where possible, quantitative assessments. In cases wher e delays or modification have altered emissions reduction estimates such that the original estimates of emissions are no longer accurate, information is also provided on th e effects of these alterations.

1.1 2007 Heavy-Duty Highway Rule (40 CFR Part 86, Subpart P)

In this regulation, EPA set a particulate m atte r (PM) emissions standard for new heavy-duty engines of 0.01 g/bhp-hr, which took full effect fo r diesel engines in the 2007 model year. This rule also included standards for oxides of nitrogen (NO X ) and non-methane hydrocarbons (NMHC) of 0.20 g/bhp-hr and 0.14 g/bhp-hr, respectively. These diesel engine NO X and NMHC standards were successfully phased in togeth er between 2007 and 2010. The rule also required
that sulfur in diesel fuel be reduced to facilitate the use of modern pollution-control technology
on these trucks and buses. The EP A required a 97 percent reducti on in the sulfur content of highway diesel fuel -- from leve ls of 500 ppm (low sulfur dies el) to 15 ppm (ultra-low sulfur diesel). These requirements were successfully implemented on the timeline in the regulation.

1.2 Tier 2 Vehicle and Gasoline Sulfur Program (40 CFR Part 80, Subpart H; 40 CFR Part 85; 40 CFR Part 86)

The EPA’s Tier 2 fleet averag ing program for on-road vehicles, modeled after the California LEV ( Low Emissions Vehicle) II standards, be came effective in the 2005 model year. The Tier 2 program allows manufacturers to produce vehicl es with emissions ranging from relatively dirty to very clean, but the mix of vehicles a manuf acturer sells each year must have average NO X emissions below a specified value

. Mobile emissions continue to benefit from this program as motorists replace older, more polluting vehicles with cleaner vehicles.

1.3 Nonroad Diesel Emissions Program (40 CFR Part 89)

The EPA adopted standards for em issions of NO X , hydrocarbons, and carbon monoxide (CO) from several groups of nonroad engines, incl uding industrial spark- ignition engines and recreational nonroad vehicles. Industrial spark-ig nition engines power commercial and industrial applications and include forklifts, electric gene rators, airport baggage transport vehicles, and a variety of farm and construction applicati ons. Nonroad recreational vehicles include snowmobiles, off-highway motorcycles, and all- terrain vehicles. These rules were initially effective in 2004 and were fully phased in by 2012.

The nonroad diesel rule set sta ndards that reduced emissions by more than 90 percent from nonroad diesel equipment and, beginning in 2007, the rule reduced fuel sulfur levels by 99 percent from previous levels. Th e reduction in fuel sulfur levels applied to most nonroad diesel fuel in 2010 and applied to fuel used in locomotives and marine vessels in 2012.SC SIPR: Regional Haze Periodic Report (December 2012) 13 1.4 Maximum Achievable Control Techno logy (MACT) Pr ograms (40 CFR Part 63)

VISTAS applied controls to future year emissi ons estimates from various MACT regulations for volatile organic compounds (VOC), SO 2 , NO X , and PM on source categories where controls were installed on or after 2002. (Requirement s to reduce toxic air emissions under these regulations also have the co benefit of reducing VOC and othe r criteria pollutant emissions.) Control estimates are documented in the report entitled, “Control Packet Development and Data Sources,” Alpine Geophysics, July 14, 2004. Ta ble 3 below describes the MACTs used as control strategies for the non-EGU point source emissions. The table notes the pollutants for which controls were applied as well as the promulgation dates and the compliance dates for existing sources.

Table 3: MACT Source Categories with Compliance Dates on or after 2002

MACT Source Category 40 CFR 63 Subpart Date Promulgated Existing
Source Compliance
Date Pollutants
Affected

Hazardous Waste Combustion (Phase I) Parts 63 (EEE),261
and 270 9/30/99 9/30/03 PM

Oil & Natural Gas Production HH 6/17/99 6/17/02 VOC

Polymers and Resins III OOO 1/20/00 1/20/03 VOC

Portland Cement Manufacturing LLL 6/14/99 6/10/02 PM

Publicly Owned Treatment Works (POTW) VVV 10/26/99 10/26/02 VOC

Secondary Aluminum Production RRR 3/23/00 3/24/03 PM

Combustion Sources at Kr aft, Soda, and Sulfite Pulp & Paper Mills (Pulp and Paper MACT II) MM 1/12/01 1/12/04 VOC

Municipal Solid Waste Landfills AAAA 1/16/03 1/16/04 VOC

Coke Ovens L 10/27/93 Phased from
1995-2010 VOC

Coke Ovens: Pushing, Quenching, and Battery

Stacks CCCCC 4/14/03 4/14/06 VOC

Asphalt Roofing Manufacturing and Asphalt
Processing (two source categories) LLLLL 4/29/03 5/1/06 VOC

Metal Furniture (Surface Coating) RRRR 5/23/03 5/23/06 VOC

Printing, Coating, and Dyeing of Fabrics OOOO 5/29/03 5/29/06 VOC

Wood Building Products (Surface Coating) QQQQ 5/28/03 5/28/06 VOC

Lime Manufacturing AAAAA 1/5/04 1/5/07 PM, SO 2

Site Remediation TSDF GGGGG 10/8/03 10/8/06 VOC

Iron & Steel Foundries EEEEE 4/22/04 04/23/07 VOC

Taconite Iron Ore Processing RRRRR 10/30/03 10/30/06 PM, SO 2SC SIPR: Regional Haze Periodic Report (December 2012) 14 MACT Source Category 40 CFR 63 Subpart Date Promulgated Existing
Source Compliance
Date Pollutants
Affected

Miscellaneous Coating Manufacturing HHHHH 12/11/03 12/11/06 VOC

Metal Can (Surface Coating) KKKK 11/13/03 11/13/06 VOC

Plastic Parts and Products (Surface Coating) PPPP 4/19/04 4/19/07 VOC

Miscellaneous Metal Parts and Products
(Surface Coating) MMMM 1/2/04 1/2/07 VOC

Industrial Boilers, Institutional/ Commercial
Boilers, and Process Heaters DDDDD 9/13/04 9/13/07 PM SO 2

Plywood and Composite Wood Products DDDD 7/30/04 10/1/07 VOC

Reciprocating Internal Combustion Engines ZZZZ 6/15/04 6/15/07 NO X , VOC

Auto and Light-Duty Truck (Surface Coating) IIII 4/26/04 4/26/07 VOC

Wet Formed Fiberglass Mat Production HHHH 4/11/02 4/11/05 VOC

Metal Coil (Surface Coating) SSSS 6/10/02 6/10/05 VOC

Paper and Other Web Coating (Surface Coating) JJJJ 12/4/02 12/4/05 VOC

Petroleum Refineries UUU 4/11/02 4/11/05 VOC

Miscellaneous Organic Chemical Production
(MON) FFFF 11/10/03 05/10/08 VOC

Use of the Industrial/Commercial/Institutional (IC I) Boiler MACT standard was problematic in that the US Court of Appeals for the District of Columbia Circuit vacated and remanded that regulation to EPA on June 8, 2007. However, VIST AS chose to leave the emissions reductions associated with this regulation in place sin ce the CAA required use of alternative control methodologies under Section 112(j) for uncontroll ed source categories. The applied MACT control efficiencies were 4 percent for SO 2 and 40 percent for course particulate matter (PM 10 ) and fine particulate matter (PM 2.5 ) to account for the co-benefit fr om installation of acid gas scrubbers and other control equipment to reduce hazardous air pollutants (HAPS).

To determine how the vacatur of this regulation may have aff ected the VISTAS future year inventories, VISTAS created an analysis of inventory data to determine the level of SO 2 , PM 10 , and PM 2.5 reductions associated with the vacated regulation. Tabl e 4 compares the level of
emission reductions for VISTAS in 2009 and 2018 estimated to be derived from the vacated regulation to the total non-EGU point source inventory for th ose years and to the total annual inventory for those years.SC SIPR: Regional Haze Periodic Report (December 2012) 15 Table 4: ICI Boiler MACT Reductions Comp ared to the 2009 and 2018 VISTAS Inventory

ICI Boiler MACT
Estimated Reductions

in VISTAS States (1) Non-EGU
Inventories for
VISTAS States (2) Total Inventories for
VISTAS States (2) Pollutant

2009 2018 2009 2018 2009 2018

Primary PM 10 , tpy -13,325 -14,556 211,267 248,367 4,161,695 4,549,680

Primary PM 2.5, tpy -10,892 -11,919 157,615 185,490 1,124,150 1,195,487

SO 2 , tpy -7,773 -8,188 548,196 575,716 3,468,899 2,169,773

(1) ICI Boiler MACT reductio n estimates taken from VISTAS Boiler_MACT_20080611.xls
(2) Data from Documentation of the BaseG2 and Best & Final 2002 Base Year, 2009 and 2018 Emission

Inventories for VISTAS-R evision 1, April 9, 2008 , Table 2.1-15, Table 2.1-19, Table 2.1-20, and Appendix A.

The emission reductions associated with the v acated ICI Boiler MACT were a very small percentage of overall non-EGU and total inventory emissions for each of the affected pollutants.
The EPA finalized the revised ICI Boiler MACT on February 21, 2011. The EPA estimated that implementation of the revised rulemaking would reduce emissions nationwide from major source boilers and process heaters by 47,000 tpy of PM, 440,000 tpy of SO 2 , and 7,000 tpy of VOCs. However, in March of 2011, the EPA published a no tice stating their inte ntion to reconsider certain aspects of the boiler and commercial a nd industrial solid waste incinerator rules and subsequently proposed the relevant changes on December 2, 2011. In August 2012, the EPA won a court order delaying until January 13, 2012, any further proceedings in litigation over the original March 2011 version of the rules. In the meantime, on February 2, 2012, EPA issued a ‘no action assurance’ letter stating that it w ill not enforce compliance or reporting deadlines in the original March 2011 rules

. South Carolina cannot provide specific emission reduction information for sources in the State given th e reconsideration has not been finalized.

1.5 Federal Consent Agreements

The VISTAS 2009 and 2018 em issions inventories t ook into account unit specific requirements from several federal consent orders applicable to source types other than electrical generation, as
described below.

 Dupont (US District Court, S outhern District of Ohio): A 2007 agreement called for the James River plant, located in Virginia, to install dual absorption pollution control equipment by September 1, 2009, resulting in emission reductions of approximately 1,000 tons of SO 2 annually. The sulfuric acid plant emitted 1,145 tons of SO 2 in 2002. In 2009, the year in which controls were applied, the plant emitted 379 tons of SO 2 , and in 2010 the plant emitted 42 tons of SO 2

.

 Stone Container (US District Court, Eastern District of Virginia): A 2004 agreement called for the West Point Paper Mill, owned by Smurfit/Stone Container and located in West Point, Virginia, to control SO 2 emissions from the #8 Power Boiler with a wet scrubber. This device was installed and opera tional in October of 2007. Emissions of SO 2 from the facility during 2002 were 4,575 tpy. Emissions of SO 2 from the facility duringSC SIPR: Regional Haze Periodic Report (December 2012) 16 2009, after installation of the scrubb er, were 1,009 tpy. Emissions of SO 2 in 2010 from the facility were 1,252 tpy.

 Santee Cooper (US District Court, South Ca rolina Charleston Division): Santee Cooper is a quasi-public South Carolina utility that ope rates four coal-fired power plants, a hydro plant, a nuclear plant, and several natural gas plants. The March 16, 2004, settlement encompasses ten units at four coal-fired pow er plants and two proposed new coal-fired units. Specifically, th e settlement requires Santee Cooper to install state-of-the-art air pollution controls on certain un its and upgrade other existing air pollution controls. The
controls will result in the removal of approximately 37,500 tons per year of SO 2 and 29,500 tons per year of NO X from Santee Cooper’s exis ting coal-fired units. The settlement also requires Sant ee Cooper to retire excess SO 2 emission allowances from its
Acid Rain allocations and restrict trade of its NO X allowances. The coal-fired power plants and their locations in South Carolina covered under this settlement include: Cross Plant located in Pineville, Berkeley Count y, SC, consisting of coal-fired units 1 (620 megawatts, or MW), 2 (540 MW), 3 (660 MW- to be constructed), and 4 (660 MW - to be constructed); Grainger Plant located in Conway, Horry County, SC, consisting of coalfired units 1 (85 MW) and 2 (85 MW); Jefferies Plant lo cated in Moncks Corner, Berkeley County, SC and consisting of coal -fired unit 3 (153 MW) and 4 (153 MW), but not including units 1 and 2, which are oil-fi red units; and the Winyah Plant located in Georgetown, Georgetown County, SC, consisting of coal-fired units 1 (295 MW), 2 (295 MW), 3 (295 MW), and 4 (270 MW). A copy of this Consent Decree can be found in Appendix B.

 INVISTA S.à.r.l. (INVISTA) ( US District Court, District of Delaware ) : On April 13, 2009, INVISTA agreed to limit its emission at it s Camden, South Carolina facility such that two of its boilers will comply with a combined NO X emissions limit of 202 tons on a 12-month rolling average basis by converting on e boiler to natural gas controlled with SCR technology, and installing Mobotec w ith Rotamix designed to reduce NO X emissions by 65 percent on an additional boiler. SO 2 from the natural gas boiler will be limited to 1 ton on a 12-month rolling average basis. INVISTA has also committed to limit sulfur content in all vaporizer fuel to 1 percent. (*INVISTA is subject to BART but refined modeling analysis conducted as part of the SC Regional Haze SIP effort indicate
its emissions were below the contribution th reshold established.) Information regarding
this consent decree was not included in the State’s Regional Haze SI P (as it postdates the submittal), however, this information is being offered as qualitative evidence that further reductions are being realize d. Appropriate updated information will be offered in the State’s next requi red SIP revision.

 Lafarge (US District Court, Southern Districtof Illinois): Lafarge operated a cement kiln in Harleyville, South Carolina, which it sold to Argos USA in 2011. Per the terms of the consent decree from January 1, 2010, Lafarge shall install a continuous emissions monitoring system (CEMs) and comply with the requirements of Permit Number 0900-0004- EF-R2, issued by the Department on December 14, 2007, as may become applicable relative
to SO 2 emissions at Harleyville Kiln 1 at the Harleyville Facility – which consists of complying with existing BACT limits. (The Lafarge kiln unit is a non-EGU that was not examined in the SC Regional Haze SIP). Information regarding this consent decree was also not included in the State’s Regional Haze SIP (as it postdates the submittal),SC SIPR: Regional Haze Periodic Report (December 2012) 17 however, this information is being offered as qualitative evidence that further reductions are being realized. A ppropriate updated information will be offered in the State’s next required SIP revision.

2. EGU Control Strategies

Em issions from EGUs have been regulated th rough a number of mechanisms, including CAIR;
the Cross State Air Pollution Rule (CSAPR); State programs; fe deral consent agreements; and various source-specific permitting actions. Reductions associated with many of these
mechanisms were used to estimate the 2018 visi bility improvements at the VISTAS Class I areas. Since development of the Best and Final in ventory, additional regulations and actions have been imposed on this source sector. These additional mandates will help ensure that RPGs are
attained on or before 2018 in each Class I area.

2.1 North Carolina Clean Smokestacks Act

In June of 2002, the North Carolina General Ass embly enacted the Clean Smokestacks Bill, which required significant actual em issions reductions from coal-f ired power plants in North Carolina. These reductions were included as pa rt of the VISTAS 2018 Be st and Final modeling effort. Under the act, power plants were required to reduce their NO X emissions by 77 percent in
2009 and their SO 2 emission by 73 percent in 2013. Actions ta ken to date by facilities subject to these requirements comply with the provisions of the Clean Sm okestacks Act, and compliance plans and schedules will allow these entities to achieve the emissions limitations set out by the Act. This program has been highly successful. In 2009, regulated entities emitted less than the 2013 system annual cap of 130, 000 tons of SO 2 and less than the 2009 system annual cap of 56,000 tons of NO X

.

2.2 Georgia Multi-Pollutant Control for El ectric Utility Stea m Generating Units

Georgia rule 391-3-1.02(2)(sss), enacted in 2007, requires FGD and SCR controls on coal fired EGUs in Georgia. Reductions from this regulati on were included as part of the VISTAS 2018 Best and Final modeling effort. These controls will reduce SO 2 emissions from the affected emissions units by at least 95 percent and will reduce NO X emissions by approximately 85 percent. Control implementation dates vary by EGU, starting on December 31, 2008.

2.3 Maryland Healthy Air Act (HAA)

The Maryland HAA reg ulations became effective on July 16, 2007, and required reductions in
NO X , SO 2 , and mercury emissions from large coal burning power plants in Maryland. Emission reductions from the HAA come in two phases. The first phase required reductions in the 2009/2010 timeframe, and compared to a 2002 emission baseline, reduced NO X emission by almost 70 percent and SO 2 emission by 80 percent. The second phase of emissions controls occurs in the 2012/2013 time frame. At full implementation, the HAA will reduce NO X emissions by approximately 75 percent from 2002 levels and SO 2 emissions by approximately 85 percent from 2002 levels. Maryland is not a VIST AS participant. However, Maryland borders two VISTAS states, and Maryland facilities ha ve calculated sulfate visibility impairment
contributions to several VISTAS Class I areas . The first phase of the HAA was successfully implemented, and the second phase of the program is expected to be implemented in a timelySC SIPR: Regional Haze Periodic Report (December 2012) 18 manner. Reductions associated with this progr am were included as part of the VISTAS 2018 Best and Final modeling effort.

2.4 Clean Air Interstate Rule and Cross State Air Pollution Rule

On May 12, 2005, the E PA promulgated CAIR, which required reductions in emissions of NO X and SO 2 from large fossil fuel fired EGUs. These emissions reductions (as shown in Table 5 below) were included as part of the VISTAS 2018 Best and Final modeling effort. The US Court of Appeals for the D.C. Circuit ruled on peti tions for review of CA IR and CAIR Federal Implementation Plans, including their provisions establishing the CAIR NO X annual and ozone
season and SO 2 trading programs. On July 11, 2008, th e Court issued an opinion vacating and remanding these rules. However, parties to the li tigation requested rehear ing of aspects of the Court’s decision, including vacating them. The December 23, 2008, ruling left CAIR in place until the EPA issues a new rule to replace CAIR in accordance with the July decision. South Carolina received approval of its CA IR SIP on October 16, 2009 (74 FR 53167).

On July 6, 2011, the EPA finalized CSAPR. EPA intended for this rule to replace CAIR beginning 2012 and requires 27 states in the eastern half of the United States to reduce power plant emissions. The EPA also issued a supplemental proposal for six states to make summer
time NO X reductions. This supplemental proposal, when finalized, would bring the total number of states participating in the program to 28. CSAPR is estimated to reduce 2005 emissions from EGUs by 6,500,000 tons of SO 2 annually and 1,400,000 tons of NO X annually in covered states. These estimates represent a 71 percent reduction in SO 2 and a 52 percent reduction in NO X from
2005 levels.

On December 30, 2011, the US Court of Appeals for the D.C. Circuit issued a ruling to stay the CSAPR pending judicial review. Oral arguments were held on April 13, 2012. On August 21, 2012, the Court of Appeals for the DC Circuit va cated CSAPR. CAIR remains in effect while EPA develops a replacement rule. South Caroli na’s CAIR regulations, at SC Regulation 61- 62.96, went into effect on May 1, 2009, replacing the NO X SIP Call Program. Sources within the State are continuing to comply with CAIR.

Table 5 provides a comparison of the emissi on budgets under the various programs aimed at reducing transport emission in S outh Carolina. While the budget num bers associated with CAIR represent a trading component and not a state-wi de limit as was intended with CSAPR, both the
emission limits and the 2011 actual emissions are ad equate to demonstrate that South Carolina is
on track to meet its RHR RPGs.

Table 5: Comparison of CAIR & CSAPR SO 2 Emission limits vs. 2011 Actual Emissions

Acid Rain Program

2010+ Budget CAIR
Phase 1
2009-14 Budget CAIR
Phase 2

2015+ Budget 2011
Actual
Emissions CSAPR
Assurance
Limit (Budget + Variability Limit)

NOx N/A 32,662 27,219 23,449 38,348SC SIPR: Regional Haze Periodic Report (December 2012) 19 Annual

NOx Ozone
Season N/A 15, 249 12,767 14,068 16,830

SO 2 111,342 57,271 40,089 66,191 104,572

Note: Data is reported as annual tons per year.

2.5 Utility Federal Consent Orders

Federal cons ent agreements with major utili ties contained remedies that imposed control requirements or other reductions in future year emissions. These requirements were taken into
account in the VISTAS 2018 Be st and Final inventory.

 Under a settlement agreement, Tampa Elect ric installed permanent emissions control equipment by 2008 to meet stringent pollution limits; implemented a series of interim pollution-reduction measures to reduce emissi ons while the permanent controls were designed and installed; and retired pollution emission allowances that Tampa Electric or others could use, or sell to others, to emit additional NO X , SO 2 , and PM.

 In the VEPCO (Dominion Power) consent agre ement, the utility agreed to spend $1.2 billion by 2013 to eliminate 237,000 tons of SO 2 and NO X emissions each year from eight coal-fired EGUs in Virginia and West Virginia. Installation of these controls proceeded well ahead of schedule.

 The Gulf Power agreement required Gulf Power to upgrade to cut NO X emission rates by 61 percent at its Crist generating plant by 2007.

 American Electric Power agreed to spend $4.6 billion dollars to e liminate 72,000 tons of
NO X emission annually by 2016 and 174,000 tons of SO 2 emissions annually by 2018 from sixteen plants located in Indiana, Ke ntucky, Ohio, Virginia, and West Virginia.

2.6 Specific EGU Estimates and Reductions

Table 6 lists all EGU units in South Carolina ha ving a calculated visibility im pact on Cape Romain of at least 1 percent, based on the analysis submitted in Appendix H of the SC Regional Haze SIP. The table shows controls assigned to th e units in 2018 as part of the Best and Final modeling effort, the current st atus of those control assignments, estimated tons of SO 2 emissions reduced (2009-2002), and actual 201 1 emissions from those units, where available from the Clean Air Markets Division (CAMD).

This source sector has been shown to be a majo r contributor to visibi lity impairment in the VISTAS Class I areas, including Cape Romain. Good progress has been made towards reducing
SO 2 emissions from this sector. Additional re ductions beyond those assumed in the Best and Final modeling are expected to be realized by 2018, further improving visibility at Class I areas.

2.7 New EGU Control Strategies

Two f ederal programs and one federal consent agreement will provide further reductions in SO 2 from this source sector, either as a result of SO 2 requirements or as co-benefit from the reduction
of HAPS. These benefits were not considered in the development of the VISTAS Best and FinalSC SIPR: Regional Haze Periodic Report (December 2012) 20 2018 inventories. Any additional SO 2 emission reduction benefits achieved by the implementation of these requirements will help to ensure that all Class I areas in VISTAS meet their RPGs in a timely manner.

2.7.1 Mercury and Air Toxics Rule

On Dece mber 16, 2011, the EPA finalized national CAA standards to reduce mercury and other toxic air pollution from coal and oil-fired power plants. The final rule established power plant emission standards for mercury, acid gases, and non-mercury metallic toxic pollutants that will prevent 90 percent of the mercury in coal burned in power plants from being emitted to the air; reduce by 88 percent the acid gas emissions from power plants; and cut power plant SO 2 emissions by 41 percent beyond the reductions e xpected from CSAPR. These reductions are expected in the 2016 time frame.

2.7.2 2010 SO 2 National Ambient Air Quality Standard (NAAQS)

On June 2, 2010, the EPA strengthened the primary NAAQS for SO 2 by revising the primary
SO 2 standard to 75 ppb averaged over one hour. This short term standard is significantly more stringent than the revoked standards of 140 ppb averaged over 24 hours and 30 ppb averaged over a year. Under the new standard, fac ilities with significant emissions of SO 2 , many of which are EGUs, will be required to demonstrate co mpliance with the standard no later than 2017. Pursuant to the CAA, states are required to subm it such demonstrations 18 months from the date of designation of a nonattainment area. The current schedule for the finalization of nonattainment
areas for SO 2 is June 2013. 2

2.7.3 Tennessee Valley Authority Federal Consent Agreement

In April of 2011, the EPA announced a settlem ent with the Tennessee Valle y Authority (TVA) to resolve alleged CAA violations at 11 of its coal fired plan ts in Alabama, Kentucky, and Tennessee. The settlement requir es TVA to invest $3 billion to $5 billion on new and upgraded state-of-the-art pollution cont rols. Once fully implemented, th e pollution controls and other required actions will address 92 percent of T VA’s coal-fired power plant capacity, reducing
emissions of NO X by 69 percent and SO 2 by 67 percent from TVA’s 2008 emissions levels. We expect Tennessee’s Department of Environmen t & Conservation to provide the specifics of TVA’s emission reductions from this agreement as part of their first five-y ear progress report.

2 “ Extension of Deadline for Promulgating Designations for the 2010 Primary Sulfur Dioxide National Ambient Air Quality Standard” (77FR46295), August 3, 2012.SC SIPR: Regional Haze Periodic Report (December 2012) 21Table 6: SC Coal Fired Power Plants:Existing and Future Expected Controlsand Emission Reduction StrategiesFacilityEmissionUnit2002 BaseYearEmissionsTons peryear (tpy)2009VISTASEmissions(tpy)Estimated TonsReduced(2002 minus2009)(tpy)ActualEmission(2011CAMD)(tpy)2018ProjectedEmissions(tpy)SO2EmissionControlIncludedin SIPProjectedControlDate inSIPStatus of Controls00123865125-273912514347NoneN/ANo additional controls00226434881-223813484140NoneN/ANo additional controlsDuke Energy: W.S.Lee(0200-0004)00343845666-357431597274NoneN/ANo additional controlsProgress Energy:Robinson(0820-0002)0018754778497045147087NoneN/ANo additional controls001394771932282179719Scrubber2003(1995)Forced oxidation added 2003,upgrade 2010002102603380688037713380Scrubber2003(1984)Forced oxidation added 2003,upgrade 200733835N/A16473835Scrubber2006Unit began operation in 2006Santee Cooper:Cross(0420-0030)43835N/A1566N/AScrubber2008Unit began operation in 20080015399407513241535NoneN/ANo additional controlsSantee Cooper:Grainger(1340-0003)002494940888611524NoneN/ANo additional controls001240NoneN/A6N/ANoneN/A(VISTAS/IPM assumed nooperation)00283NoneN/A6N/ANoneN/A(VISTAS/IPM assumed nooperation)003113157677363831896761NoneN/ANo additional controlsSantee Cooper:Jefferies(0420-0003)004117897259453033086609NoneN/ANo additional controls00118181184216339275681Scrubber2003FGD began operation in 20070021029818428456348681Scrubber2003Upgraded FGD beganoperation in 2007003497168442871895684Scrubber2003Consent Decree requires FGDupdate in 2012Santee Cooper:Winyah(1140-0005)00436206892931992689Scrubber2006Consent Decree required FGDupdate in 20070016214571549938445203NoneN/ANo additional controls0026585564993645885144NoneN/ANo additional controlsSCE&G: Canadys(0740-0002)003792482970957200757NoneN/AVISTAS assumed ScrubberFacilityEmissionUnit2002 BaseYearEmissionsTons peryear (tpy)2009VISTASEmissions(tpy)Estimated TonsReduced(2002 minus2009)(tpy)ActualEmission(2011CAMD)(tpy)2018ProjectedEmissions(tpy)SO2EmissionControlIncludedin SIPProjecteStatus of ControlsdControlDate inSIP2009, 2012, 2018, IPM did not(Baghouse 1998*, no FGD)SCE&G: Cope(1860-0044)0011712148922315751087Scrubber1996No additional controls001546854095935014944NoneN/ALow Sulfur Coal (< 1%) partof MOA 6/2011(Baghouse 1992)*SCE&G: McMeekin(1560-0003)00264015400100137174936NoneN/ALow Sulfur Coal (< 1%) partof MOA 6/2011(Baghouse 1993)*SCE&G: Urquhart(0080-0011)356954506118947033676NoneN/ANo additional controls0011880317101709319041502ScrubberN/AFGD began operation in 2010(VISTAS assumed in2009/IPM did not)SCE&G: Wateree(1900-0013)002182071741164661979875ScrubberN/AFGD began operation in 2010(VISTAS assumed in 2009,IPM in 2018)SCE&G: Williams(0420-0006)0012269825457-27596071280Scrubber2002FGD began operation in 2010(VISTAS/IPM assumed in2018)Total2029261212866613176291*Notations for Baghouses were not included in SC RegionalHaze SIP based on the Department’s decision to focus on SO2Emission Controls.For a list of these units expected to be retired, please see Table 11 below and Appendix B.SC SIPR: Regional Haze Periodic Report (December 2012) 223. Review of BART Determinations

The VISTAS Best and Final 2018 emissions i nventories contained emissions reductions expected to be achieved from BART dete rminations made by the member States. Figure 2 shows
the 200 km radius around the Cape Romain W ilderness Area. This figure also depicts the facilities in nearby states contai ning units that are subject-to-B ART. The results of the BART
determinations for facilities located in South Carolina are listed in Table 7.

Figure 2: Subject-to-BART Facilities and Proximity to Cape Romain Wilderness Area

3.1 South Carolina

Table 7 lists the BART determ inations made in South Carolina. More information on these analyses and determinations may be found in Chap ter 7 (7.8) of the SC Regional Haze SIP. As outlined in Appendices H.4, H.5, and H.6 BART modeling sensitivitie s indicate that no additional controls were needed during this control period.

SC SIPR: Regional Haze Periodic Report (December 2012) 233.2 North Carolina

Two facilities located in North Carolina were subject to BART, Blue Ridge Paper in Canton, North Carolina and PCS Phosphate in Aurora, Nort h Carolina. As Figure 2 depicts both of these facilities are great distances from Cape Romain. Existing controls at both facilities were deemed to be BART by North Carolina, as documented in Appendix L of the SC Regional Haze SIP for NC Class I Areas, dated December 17, 2007. 3

3.3 Georgia

Two non-EGU facilities located within Cape Rom ain’s AOI in Georgia were subject to BART, International Paper, Savannah, Georgia, and In ternational Paper Savannah Electric – McIntosh, Georgia. Only one Georgia EGU, Savannah Electric McIntosh Steam, is located within Cape Romain’s AOI. However, because this EGU is s ubject to CAIR, no further analysis was required in the SC Regional Haze SIP.

Table 7: South Carolina BART Determinations

Facility Class I Area Impact (Change in dv) Modeling Analysis
Results Albemarle Corp. VOC Exempt N/A BP Amoco Chemical - Cooper
River Plant VOC Exempt N/A

Rhodia - Charleston VOC Exempt N/A

Eastman Chemical VOC Exempt N/A INVISTA - Spartanburg VOC Exempt N/A Stone Container - Florence (now RockTenn Co.) Cape Romain VISTAS Exempt N/A

ISG Georgetown Cape Romain VISTAS Exempt N/A Owens Corning - Anderson Model Plant Exempt N/A Milliken Chemical - Dewey Model Plant Exempt N/A

DAK Americas Cape Romain
Wolf Island 0.471 Below 0.5 threshold*

MeadWestvaco Corp. (now Kapstone) Cape Romain
Okefenokee
Wolf Island 0.438 Screened below 0.5
threshold**

SCE&G - Canadys Cape Romain
Okefenokee
Wolf Island 0.341 Screened below 0.5
threshold

International Paper - Georgetown Cape Romain
Wolf Island 0.456 Below 0.5 threshold*

Wellman - Palmetto Cape Romain Linville Gorge Shining Rock 0.224 Screened below 0.5
threshold

INVISTA - Camden Plant Cape Romain
Great Smokies Linville Gorge Shining Rock 0.244 Screened below 0.5
threshold

Bowater (now Resolute Forest Products) Cape Romain
Great Smokies 0.381 Screened below 0.5
threshold

3 Regional Haze SIP for North Carolina Clas s I Areas, December 17, 2007, page iii.

SC SIPR: Regional Haze Periodic Report (December 2012) 24Facility Class I Area Impact (Change in dv) Modeling Analysis
Results Joyce Kilmer Linville Gorge Shining Rock Santee Cooper - Jeffries Cape Romain
Wolf Island 0.318 Screened below 0.5
threshold

SCE&G - Williams Cape Romain
Okefenokee
Wolf Island 1.83 FGD

Santee Cooper - Winyah Cape Romain
Wolf Island 0.476 Below 0.5 threshold*

Santee Cooper - Grainger Cape Romain Swanquarter 0.235** Screened below 0.5
threshold

SCE&G - Wateree Cape Romain
Great Smokies Linville Gorge Shining Rock
Wolf Island 0.95 FGD

* See Sea Salt analysis from re fined modeling technique – Appendi x O from SC Regional Haze SIP ** MeadWestvaco (Kapstone) also accepted limits in the Title V permit renewal to limit SO 2 emissions

SC SIPR: Regional Haze Periodic Report (December 2012) 25SC SIPR: Regional Haze Periodic Report (December 2012) 26 4.0 Reasonable Progress Determinations

Regional air quality m odeling proj ected that reductions in SO 2 from EGU and non-EGU point sources would result in the greatest improveme nts in visibility at VISTAS Class I areas. Therefore, for this first round of regional h aze planning, VISTAS chose to focus reasonable progress evaluations on potential SO 2 emission controls from these source sectors. To select the specific point sources that would be considered fo r each Class I area, states first identified the geographic areas that most likely in fluenced visibility in each Cla ss I area and then identified the major SO 2 point sources in that geographic area. VISTAS created detailed spreadsheets identifying SO 2 emissions by stack, distance from Class I areas, and estimated sulfate extinctionweighted residence times.

To further aid in the reasonable progress analyses, AirControlNET results were used. AirControlNET, a control technology analysis tool developed to support the EPA in its analyses of air pollution policies and regul ations, provided data on emissi on sources, potential pollution control measures, emission reductions, and the costs of implementing those controls. Every
available SO 2 control strategy in AirControlNET was run against the EGU and non-EGU point source inventories to develop a master list of ava ilable, increment control strategies for VISTAS states to use in reasonable pr ogress controls development. Stat es reviewed stacks with an estimated calculated sulfate visibility contributio n of at least 1 percent to any Class I area to
determine if further SO 2 controls were feasible. South Carolina used a benchmark of approximately $2,000/ton of pollutant removed to determine economic feasibility. 4 Units identified by AirControlNET as potentially havi ng the opportunity for cost-effective control
installation were asked to subm it a reasonable progress four fact or analysis. Mo re detail on the methodology of the VISTAS reasonable progress an alysis may be found in Appendix H of South Carolina’s Regional Haze SIP.

After review of all data, South Carolina determined that no sour ces required further analysis to satisfy reasonable progress requirements during the first round of regi onal haze planning.

4.1 Emission Control Measures Not Included in the Best and Final Inventory Effort

Since developm ent of the 2018 Best and Final in ventory effort, a number of regulations and requirements have been promulgated that were not included in 2018 estimates. The sections below provide information on these requirements, and where possible, estimates of additional reductions are provided. These reductions provide extra assurances that Cape Romain will meet its RPGs in a timely manner.

4.2 North American Emission Control Area

On M arch 26, 2010, the Internati onal Maritim e Organization offici ally designated waters off
North American coasts as an area in which stri ngent international emission standards will apply to ships. These standards will reduce air pollution from ships and deliver air quality benefits that

4 See Section 7.7 of SC DHEC, South Carolina Regional Haze State Implementation Plan for South Carolina Class
I Federal Areas , dated December 21, 2007 (Available at http://www.scdhec.gov/environment/baq/docs/regs/other/SIPR%2020071221.pdf , last visited October 25, 2012).extend hundreds of miles inland. In 2020, EPA exp ects emissions from ships operating in the designated area to be reduced by 320,000 tons for NO X , 90,000 tons for PM 2.5 , and 920,000 tons
for SO 2 , which is 23 percent, 74 percent, and 86 per cent, respectively, below predicted levels in
2020 absent the Emissions Control Area designation.

Imp lementation of the Emission Control Area means that ships entering the designated area would need to use compliant fuel for the durati on of their voyage that is within that area, including time in port as well as voyages whos e routes pass through the area without calling on a port. The requirements for quality of fuel change over time. From the effective date in 2012 until 2015, fuel used by all vessels operating in designated areas cannot exceed 10,000 ppm. Beginning in 2015, fuel used by vessels operating in these areas cannot exceed 1,000 ppm, and beginning in 2016, NO X after-treatment requirements become applicable.

4.3 Residual Risk Requirements

The CAA re quires the EPA to assess the risk remaining after applica tion of final technologybased air toxics standards to any source category within 8 years of sett ing the technology based MACT standards. In the residual risk process, the EPA must assess the remaining health risks from each source category to determine whether the MACT standards provide an ample margin of safety to protect public heal th and protect against adverse e nvironmental effects. Final rules for this CAA requirement are expected for 28 source categories between 2011 and 2013. Additional requirements to reduce toxic air emi ssions under the residual risk assessment may
also have co benefits for the reduction of VOC and other crite ria pollutant emissions between
now and 2018.

4.4 Control Technique Guidelines

The federal CAA (§ 172(c)(1)) provides that SIPs for nonattainm ent areas must include reasonably available control techniques (RACT) fo r control of emissions that contribute to the formation of ozone air pollution. Section 182(b)(2) provides that for certain nonattainment areas,
states must revise their SIPs to include RA CT for sources of VOC emissions covered by a control techniques guidelines docu ment (CTG). Section 183(e) then directs the EPA to list for regulation those categories of products that accoun t for at least 80 percen t of the VOC emissions from commercial products in ozone nonattainment areas.

RACT controls for source categories contro lled by a CTG are known as CTG RACTs. CTG RACTs have been issued for various printi ng, coating, and cleaning operations. In 2006, 2007, and 2008, the EPA published CTGs as listed in Table 8.

South Carolina provided an analys is of these sources for the st ate’s single nonattainment area (the York County portion of the Rock H ill-Fort Mill Area Trans portation Study (RFATS) Metropolitan Planning Organization (MPO) as part of the Charlotte-Gastonia-Rock Hill, North Carolina-South Carolina (Metro lina) nonattainment area). This certification included negative declarations for certain source categories, meanin g that the Department concluded that no such sources are located in the York County portion of the Metrolina nonatt ainment area. The EPA evaluated the proposed revisions to South Carolina’s SIP, and conc luded that they are consistent with statutory and regulatory requirements a nd EPA guidance. As a result, on November 28,

SC SIPR: Regional Haze Periodic Report (December 2012) 272011, the EPA via direct final approval (76 FR 72844) took action to approve South Carolina’s
SIP.

Table 8: CTGs Promulgated in 2006, 2007, and 2008

Category EPA Document
Number

Industrial Cleaning Solvents EPA-453/R-06-001
Offset Lithographic Printing and Letterpress Printing EPA-453/R-06-002

Flexible Package Printing EPA-453/R-06-003

Flat Wood Paneling Coatings EPA-453/R-06-004

Paper, Film, and Foil Coatings EPA-453/R-07-003

Large Appliance Coatings EPA-453/R-07-004

Metal Furniture Coating EPA-453/R-07-005

Miscellaneous Metal and Plastic Parts Coatings EPA-453/R-08-003

Fiberglass Boat Manufacturing
Materials EPA-453/R-08-004

Miscellaneous Industrial Adhesives EPA-453/R-08-005
Automobile and Light-Duty Truck Assembly Coatings EPA-453/R-08-006

40 CFR 51.308(g)(2): Summary of Reductions Achieved

40 CFR 51.308(g)(2) of the RHR requires, “ A summary of the emissi ons reductions achieved throughout the State through implementation of the measures in paragraph (g)(1).”

5. Overall SO 2 Emission Reductions

As in the original SIP submittal, this periodic update is focused on the largest contributor to visibility impairment, sulfates. Overall SO 2 emissions have decreased in South Carolina.

5.1 EGU SO 2 Emission Reductions and Utilization

The large reductions in SO 2 emissions from electric generating units during 2009 resulted from many factors, including c ontrol installations, units switching to cleaner fuels, load shifting from dirtier units to cleaner units, and an overall decrease in dema nd for generation. CAMD data for Acid Rain Program units from 2002 thr ough 2011 indicate that reductions in SO 2 emissions appear to be maintained, and further reductions achieved, even though heat input to these units

SC SIPR: Regional Haze Periodic Report (December 2012) 28increased between 2009 and 2010. This generality is true for South Carolina EGUs and across
VISTAS.

Figure 3: South Carolina Acid Rain Progr am Unit Emissions and Heat Input Data

(source: USEPA CAMD Database)

Figure 3 depicts the trends for South Carolina’ s Acid Rain Program un its that report annual emissions to CAMD. Between 2002 and 2011, heat inpu t to these units actually increased from approximately 418,577,515 mmbtu to 443,900,798 mmbtu. However, actual SO 2 emissions from these units decreased from 199,118 tons annuall y in 2002 to 66,166 tons annually in 2011, a decrease of 67 percent, and the average SO 2 emission rate from these units decreased from 0.951
lbs SO 2 /mmbtu in 2002 to 0.298 lbs SO 2 /mmbtu in 2011, a decrease of 69 percent. The
reductions in emissions demonstrate that even w ith an increase in demand for power, as evinced by the increased heat input to these units ; a significant redu ction to overall SO 2 emissions
occurred due to the installa tion of controls and the use of cleaner burning fuels.

A comparison of 2009 and 2011 data for South Ca rolina shows similar results. Emissions fell from 93,941 tons of SO 2 in 2009 to 66,166 tons of SO 2 in 2011, and the emissions rate dropped
from 0.459 lbs SO 2 /mmbtu to 0.298 lbs SO 2 /mmbtu. The overall South Carolina emission rate is expected to continue to drop in 2012 due to th e start up of additional sc rubbing capacity and to

SC SIPR: Regional Haze Periodic Report (December 2012) 29fuel switches. (CAMD heat input data for S outh Carolina dropped only slightly for 2011, to 444,000,000 mmbtu, indicating SO 2 reductions are not from economic conditions.)

Figure 4: VISTAS Acid Rain Program Unit Emissions and Heat Input Data

(source: USEPA CAMD Database)

Figure 4 shows the trends for the Acid Rain Program units across all VISTAS states. Between 2002 and 2011, heat input to these units decreased from 7,645,295,464 mmbtu to 7,336,055,333 mmbtu, a decrease of 4.0 percent. SO 2 emissions from these units decreased from 3,713,262 tons annually in 2002 to 1,116,572 tons annually in 2011, a decrease of 69.9 percent, and the average
SO 2 emission rate from these units decreased from 0.971 lbs SO 2 /mmbtu in 2002 to 0.318 lbs
SO 2 /mmbtu in 2011, a decrease of 67.3 percent. As a dditional controls are installed to meet the stringent requirements of CSAPR and MATS, this emission rate may decrease even further.

Between 2009 and 2011, the total VISTAS states’ heat input for Acid Rain Program units increased from 6,966,765,915 mmbtu to 7,336,055,333 mmbtu. Emissions dropped in the
VISTAS states for these un its from 1,619,348 tons of SO 2 in 2009 to 1,166,572 tons of SO 2 in 2011, and the emission rates of SO 2 fell from 0.465 lbs/mmbtu to 0.318 lbs/mmbtu.

Since sulfates have been shown to be the predom inant species of concern to visibility impairment at Cape Romain during the first round of re gional haze planning, visibility improvements from

SC SIPR: Regional Haze Periodic Report (December 2012) 30reduced sulfate contribution shoul d continue into the future even though demand for power and heat input to these units may increase. Table 9 summarizes these numbers for VISTAS states and
for South Carolina.

Table 9: Comparison of Acid Rain Program Data for 2002, 2009, 2010, and 2011

VISTAS Acid Rain Unit Data South Carolina Acid Rain Unit Data

Year Heat Input

mmbtu/hr SO 2 Emissions
tons/year SO 2 Rate

lbs/mmbtu Heat Input

mmbtu/hr SO 2 Emissions
tons/year SO 2 Rate

lbs/mmbtu

2002 7,645,295,464 3,713,262 0.971 418,577,515 199,118 0.951

2009 6,966,765,915 1,619,348 0.465 427,136,370 97,940 0.459

2010 7,760,905,869 1,415,331 0.365 472,658,956 94,613 0.400

2011 7,336,055,333 7,166,572 0.318 443,900,797 66,166

Data for Acid Rain Program units, USEPA CAMD Database – 2011 Data is Preliminary 0.298

5.2 Additional EGU SO 2 Emission Reductions

Moreover, as depicted in Figure 5, SC had 2007 SO 2 emissions that were well above the 2009
modeled values. This reduction occurred because se veral sources did not have controls installed until after the initial SC Regional Haze SI Ps was submitted and VISTAS modeling was conducted. Please see Tables 10 and 11 for specific information on the types of and status of
these controls.

SC SIPR: Regional Haze Periodic Report (December 2012) 31Figure 5: South Carolina SO 2 Emission Reductions



# South Carolina SO2 Emissions

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000

2002A 2002T 2007 2009G2 2009G4 2018G2 2018G4Emissions(TPY)

Fires

Nonroad

Onroad

Area

Point

Note: VISTAS states worked in conjunction to define the source categories outlined above. The X axis of the table compares the various emission inventory iterations . More information on
these definitions and emission summaries can be found in Appendix D of the SC Regional Haze
SIP.

Figure 6 shows several EGUs in South Caro lina have seen marked decreases in SO 2 emissions over the last several years. An analysis of South Carolina Electr ic & Gas (SCE&G) facilities in
the state indicates that SO 2 emissions over the last three years have decreased significantly (see Appendix B for more detail). Moreover, for many of the SCE&G sources that showed slight increases over the last three years, SCE&G rece ntly announced, as part of the annual Integrated
Resource Plan filed with the Public Service Comm ission of South Carolina, its plans to retire up to six coal-fired generating units at three lo cations by the end of 2018 (specifically units at Canadys, McMeekin, and Urquhart – see Table 11). 5

5 SCANA, SCE&G Announces Plans to Retire a Portion of its Coal-fired Generation , May 30, 2012 (Available at http://www.scana.com/en/news-room/curren t-news-releases/sceg-announces-pla ns-to-retire-a-portion-of-its-coalfired-generation.htm , last visited October 25, 2012).

SC SIPR: Regional Haze Periodic Report (December 2012) 32Fig ure 6: SCE&G Network SO 2 Emission Reductions

SCE&G Network of PC-Fired Facilities

0 20,000 40,000 60,000 80,000 100,000 120,00019971998199920002001200220032004200520062007200820092010

YearSO2 Tons Canadys

Cope

McMeekin

Urquhart

Wateree

Williams

Network
Sum Running Average

5.3 Unit Specific Point Source Reductions

As Table 10 indicates, several South Carolina E GUs installed additional SO 2 controls after 2007. For example, as noted, scrubbers were installe d at SCE&G Williams un it 001 and Wateree units 001 and 002 in 2010, resulting in significant additional SO 2 emission reductions not accounted for in the original VISTAS modeling scenarios. As the table indicates, emissions have steadily decreased due to these controls; a decr ease from 73,679 in 2007 to just 13,897 in 2011.

SC SIPR: Regional Haze Periodic Report (December 2012) 33Table 10: Summary of South Carolina EGU SO 2 Controls between 2007 and 2011

Facility Emissions
Unit Emission
Controls Projected
Control
Date in SIP 2007 SO 2 Emissions

(TPY) 2009 SO 2 Emissions

(TPY) 2011 SO 2 Emissions

(TPY)

001 Scrubber 2003/2007 5796 1,842 275

002 Scrubber 2003/2007 3983 1,842 348

003 Scrubber 2003 Santee Cooper: Winyah (1140-0005) 004 Scrubber 2006

001 Scrubber 2003 (1995)

002 Scrubber 2003 (1984)

3 Scrubber 2006 Santee Cooper: Cross (0420-0030) 4 Scrubber 2008 no 2007
data 3,835 1566

001 Scrubber 2010 15076 1,710 1904 SCE&G: Wateree (1900-0013) 002 Scrubber 2010 15863 1,741 1979

001 Low Sulfur Coal 06/2011 6139 5,409 3501 McMeekin (1560-0003) 002 Low Sulfur Coal 06/2011 4328 5,400 3717

SCE&G: Williams (0420-0006) 001 Scrubber 2010 22494 25,457 607

TOTAL 73679 47236 13897

Table 11 goes on to denote specific additiona l point source reductions based on planned or already announced retirem ents a nd conversion to natural gas.

SC SIPR: Regional Haze Periodic Report (December 2012) 34Table 11: Unit Specific Reductions Not Incl uded in the 2018 Best and Final Inventory

Facility Emissions
Unit Emission
Control Estimated
SO 2 Emission (2011 CAMD) Projected
Control
Date in SIP Status of Controls

001 Scrubber 275 2003/2007 Upgraded FGD installed in 2007

002 Scrubber 348 2003/2007 Upgraded FGD installed in 2007

003 Scrubber 1895 2003 Upgraded FGD installed 2012 Santee Cooper: Winyah (1140-0005) 004 Scrubber 992 2006 Upgraded FGD installed in 2007
Duke (Progress Energy): H. B.
Robinson (0820-0002) 1 None
4514 N/A

Unit to be retired in 2012

001 None 1251 2015 Convert to Natural Gas 2015,
Retire 2018

002 None 1348 2015 Convert to Natural Gas 2015,
Retire 2018 Duke Energy:

W.S. Lee (0200-0004) 003 None 3159 2015 Convert to Natural Gas 2015,
Retire 2018

001 Scrubber 2179 2003 (1995) Upgraded FGD installed 2010

002 Scrubber 3770 2003 (1984) Upgraded FGD installed 2007

003 Scrubber 1647 2006 FGD installed 2006 at startup Santee Cooper:
Cross (0420-0030) 004 Scrubber 1566 2008 FGD installed 2008 at startup

001 None 1535 N/A Expected to be retired by 2018 Santee Cooper: Grainger (1340-0003) 002 None 1524 N/A Expected to be retired by 2018

001 (oil) None 6 N/A Expected to be retired by 2018 002 (oil) None 6 N/A Expected to be retired by 2018

003 None 3189 N/A Expected to be retired by 2018 Santee Cooper:
Jefferies (0420-0003) 004 None 3308 N/A Expected to be retired by 2018

001 Retire 3844 2012 Retire 2012

002 Convert to
Natural
Gas/Retire 4588 2015/2017 Convert to Natural Gas 2015 &
Retire 2017 SCE&G: Canadys (0740-0002) 003 Convert to
Natural
Gas/Retire 7200 2015/2017 VISTAS assumed Scrubber 2009, 2012, 2018 IPM did not, Convert to Natural
Gas 2015 &
Retire 2017

001 Convert to
Natural
Gas/Retire 3501 2015/2018 Low Sulfur Coal (< 1%) part of MOA 6/2011, Convert to Natural
Gas 2015 & Retire 2018 SCE&G:
McMeekin (1560-0003) 002 Convert to
Natural Gas 3717 2015 Low Sulfur Coal (< 1%) part of MOA 6/2011, Convert to Natural
Gas 2015 & Retire 2018

SCE&G: Urquhart (0080-0011) 3 Convert to
Natural
Gas/Retire 4703 2012/2018 Convert to Natural Gas 2012 &
Retire 2018

Total: 60,065

SC SIPR: Regional Haze Periodic Report (December 2012) 35The additional reductions (marked by 60,065 tons/year of SO 2 emissions based on 2011 CAMD emissions) will further help to ensure that Cape Romain will achieve th e RPGs for visibility improvement by 2018.

40 CFR 51.308(g)(3): Assessment of Visibility Conditions

4 0 CFR 51.308(g)(3) of the RHR requires, “ For each Class I area in the state, an assessment of the following visibility conditi ons and changes, with values fo r most impaired and least impaired days expressed in terms of 5 year averages of these annual values:

 51.308(g)(3)(i): Current visibility conditions for the most and least impaired days.

 51.308(g)(3)(ii): Difference between current visibilit y conditions for the most impaired and least impaired days and baseline visibility conditions.

 51.308(g)(3)(iii): Change in visibility impairment for the most impaired and least impaired days over the past 5 years.

6. Reasonable Progress Goals

The RHR at 40 CFR Section 51.308(d)(1) requires St ates to establish RPGs (in dv) for each
Class I Federal area with in the state that provide for reasonable progress towards achieving natural visibility. In the SC Regional Haze SIP, the Department established a RPG of a 3.8 dv reduction in visibility impairment by 2018, which is consistent with the uniform rate of progress needed to achieve a natural background condi tion of 12.1 dv by 2064. Likewise, South Carolina has also adopted a RPG for the 20 percent best days that would result in a 1.4 dv reduction in visibility impairment (see Table 12).

VISTAS made several improvements to the emissi ons inventory to improve model performance. The SC Regional Haze SIP was developed using the BaseG2 emission inventory (available August 2006). A final iteration of the emissions i nventory known as BaseG4 was made available in 2008. The result of this change to the inventory led to slight ch ange in the calculation of the RPG (see Table 12). The Department requests that EPA acknowledge this update to the State’s RPGs as a revision to the SC Regional Haze SIP.

Table 12: Reasonable Progress Goals for SC

Class I Area Cape
Romain Baseline Visibility,
20 % Worst Days Reasonable Progress Goal (Deciview Improvement Expected by

2018, 20% Worst Days) Baseline Visibility,
20% Best Days Reasonable Progress Goal (Expected Visibility Degradation, 20% Best Days)

BaseG2 EI 26.5 22.7 (3.8) 14.2 12.7 (1.4)

BaseG4 EI 26.5 22.7 (3.8) 14.3 12.8 (1.5)

SC SIPR: Regional Haze Periodic Report (December 2012) 366.1 Visibility Conditions

An analysis of emission reductions in South Ca rolina indicates that the state is on track to achieve these goals in 2018. Figures 7, 8, 9, and 10 address the 3 requirements at 40 CFR 51.308(g)(3) and depict the current visibility cond itions, the difference between current visibility and baseline visibility, and a fi ve-year rolling average for the mo st (20 percent worst) and least (20 percent best) days at Cape Romain. As indicated by these figures, visibility at Cape Romain has significantly improved since 2000.

Figure 7 shows that recent observations demonstrat e visibility on the 20 per cent best days is at the glide path. Even when examining the changes in visibility impairment for the least impaired days, taken over a five-year rolling average, Cape Romain is meeting its RPG. Moreover, expected future reductions in SO 2 emissions based on further controls, shutdowns, and conversions to either natural gas or lower sulf ur fuels (see Appendix B and Tables 10 and 11)
will serve to continue this downw ard trend in the coming years.

In addition to improvement in visibility on th e 20 percent best visi bility days, Figure 8 demonstrates that visibility on the 20 percent worst days is projected to be below the glideslope in 2018 at Cape Romain. The changes in visibility impairment for the most impaired days have dropped significantly over the la st few years. Taken over a five-year rolling average, Cape Romain is expected to meet its RPG in 2018.

Figures 9 and 10 depicts the glideslope for Cape Romain as outlined in the recent report describing aerosol speciation data collected by th e Interagency Monitoring of Protected Visual Environments (IMPROVE) network and taken from Attachment G (Supplemental Analysis for Chapter 9). 6 Specifically, the figure shows baseli ne (2000-2004) and period 1 (2005-2009) 20 percent worst and 20 percent best visibility es timates and natural condition targets for tracking progress under the RHR for Cape Romain.

As discussed in the SC Regional Haze SIP, the gr eatest benefits on the 20 percent worst days for Cape Romain were projected to result from further reducing SO 2 from EGUs. As outlined in Section 5, the reductions from SO 2 emissions from EGUs in SC have been significant and are only expected to continue over the next five years.

The Department committed in the SC Regional H aze SIP to re-examine the need for additional non-EGU controls during this, the state’s five-y ear progress report. However, as evidenced by
the current and future SO 2 emission reductions from EGUs, furt her reductions from non-utility, industrial point sources continues to be unnecessary at this time.

6 Jenny Hand, Spatial and Seasonal Patterns and Temporal Variability of Haze and its Constituents in the United States: Report V , June 2011 (Available from http://vista.cira.colostate.edu/improve/Publications/Reports/2011/2011.htm ).

SC SIPR: Regional Haze Periodic Report (December 2012) 37SC SIPR: Regional Haze Periodic Report (December 2012)3814.29 14.29 14.295.9213.1612.76051015202530352000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Haziness Index (Deciviews)YearReasonable Progress Assessment Base G2 inventory,new IMPROVE AlgorithmCape Romain - Best 20% DaysBaselineNatural Condition (20% Best Days)ObservationMethod 1 PredictionRolling AverageFigure 7: Rate of Progress Glidepath for 20% Best Days at Cape Romain, SCFigure 8: Rate of Progress Glidepath for 20% Worst Days at Cape Romain, SC25.2823.1220.7318.3315.9413.5412.1026.4824.4622.65051015202530352000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Haziness Index (Deciviews)YearUniform Rate of Reasonable Progress Glide PathCape Romain - W20% Data DaysGlide PathNatural Condition (Worst Days)ObservationMethod 1 PredictionRolling AverageSC SIPR: Regional Haze Periodic Report (December 2012)39Figure 9: Rate of Progress Glidepath for 20% Worst Days atCape Romain, SCSC SIPR: Regional Haze Periodic Report (December 2012)40Figure 10: Rate of Progress Glidepath for 20% Best Days atCape Romain, SCSC SIPR: Regional Haze Periodic Report (December 2012)41SC SIPR: Regional Haze Periodic Report (December 2012) 42 40 CFR 51.308(g)(4): Emissions Tracking by Source Category

40 CFR 51.308(g)(4), of the RHR requires an, “ Analysis tracking the change over the past 5 years in emissions of pollutants contributing to visibility impa irment from all sources and activities within the state. Emissions changes shou ld be identified by type of source or activity. The analysis must be based on the most recentl y updated emissions inven tory, with estimates projected forward as necessary and appropriate, to account for emissions changes during the applicable 5 year period.”

Moreover, the RHR (64 FR 35747) goes on to require that, “Each 5 year progress report must contain...An emissions tracking re port that analyzes the chan ge over the past 5 years in emissions of pollutants contributing to visibility impairment, disaggregated by source category and emissions activity, for significant ca tegories of sources or activities.”

40 CFR 51.308(d)(4)(v) of the RHR requires a statew ide emissions inventory of pollutants that are reasonably anticipated to cause or contribute to visibility impairment. As such, the VISTAS states developed an inventory for the baseline year 2002, along with estimated inventories for future years of 2009 and 2018. The pollu tants inventoried include VOCs, NO X , PM 2.5 , PM 10 , ammonia, and SO 2 . Five emission inventory source classifications were developed and include: Stationary point and area sources, off-road a nd on-road mobile sources, and biogenic sources. Throughout the course of its wo rk to develop the Regional Ha ze SIPs, VISTAS made several improvements to the emissions inventory to impr ove model performance. Appendix D of the SC Regional Haze SIP describes in depth the state’s efforts with regard to the initial emission inventory development and subsequent emission tracking.

The SC Regional Haze SIP was developed using the BaseG2 Emission Inventory. A final iteration of the emissions inventory known as BaseG4 was made available in 2008. Tables 13, 14, and 15 compare the projected 2018 BaseG4 inventory to the 2007 Emission Inventory, and
the 2002 Base Year-Actual Inventories.

Table 13: South Carolina 2018 BaseG4 Emissions Inventory by Source Sector

State FIPS CO NH 3 NO X PM 10 - PRI PM 25 - PRI SO 2 VOC

SC Point 83,390 2,404 95,082 42,314 34,493 147,787 42,918

Area 83,167 33,496 20,592 304,251 44,319 13,457 161,228

Onroad 663,493 6,473 43,490 2,184 1,087 643 46,301

Nonroad 481,332 41 31,758 2,617 2,474 1,198 36,131

Fires 282,307 1,039 5,899 29,153 25,955 1,359 16,045

Total 1,593,689 43,453 196,821 380,519 108,328 164,444 302,623Table 14: South Carolina 2007 Emissions Inventory by Source Sector

State FIPS CO NH 3 NO X PM 10 - PRI PM 25 - PRI SO 2 VOC

SC Point 60,375 1,124 81,220 30,605 23,493 216,125 29,281

Area 32,208 30,248 9,353 266,749 39,538 6,048 76,838

Onroad 690,963 2,303 207,913 6,427 4,957 1,314 49,835

Nonroad 341,207 34 38,242 3,305 3,079 2,978 43,811

Fires 198,567 1,474 7,664 30,431 28,149 1,588 16,336

Total 1,323,320 35,183 344,392 337,517 99,216 228,053 216,101

Table 15: South Carolina 2002 Actual Emissions Inventory by Source Sector

State FIPS CO NH 3 NO X PM 10 - PRI PM 25 - PRI SO 2 VOC

SC Point 63,305 1,553 130,394 35,542 27,399 259,916 38,927

Area 113,714 28,166 19,332 260,858 40,291 12,900 161,000

Onroad 1,241,359 4,694 140,489 3,452 2,501 5,972 116,163

Nonroad 413,964 33 50,249 4,152 3,945 4,866 55,016

Fires 248,341 980 4,932 25,968 22,953 1,281 14,202

Total 2,080,683 35,426 345,396 329,972 97,089 284,935 385,308

See also response provided for 40 CFR 51, 308(g)(2): Summary of Reductions Achieved for more information related to changed in em issions from point source emissions.

40 CFR 51.308(g)(5): Changes to Anthropogenic Emissions

40 CFR 51.308(g)(5), of the RHR, requires an “ Assessment of any sign ificant changes in anthropogenic emissions within or outside the stat e that have occurred over the past 5 years that have limited or impeded progress in reducing pollutant emissions and improving visibility.”

7. Measured Progress

Figure 11 in dicates that sulfates co ntinue to be the biggest single contributor to regional haze at Cape Romain. As indicated, the Department focu sed its analysis for the SC Regional Haze SIP on addressing large SO 2 emission from point sources. To this end, as evidenced by the data in Figures 3, 4, and 6 above, there have been signif icant changes in this anthropogenic emission of concern. However, these changes have not impeded progress in reducing emissions and improving visibility, rather , the controls coupled with planne d shut downs or fuel conversions will bring us closer to reaching our RPGs.

SC SIPR: Regional Haze Periodic Report (December 2012) 43Figure 11: 5-Year Extinction for the Major Comp onents of Regional Ha ze at Cape Romain

While the existing and planned future controls ove r the next 5 years are expected to allow the state to meet its RPG, the Department in addressing the requirements at 40 CFR 51.308(g)(5), sought to further examine other po tential pollutants of concern affecting visibility at Cape
Romain.

After ammonium sulfate (64.1 per cent), the next largest fracti on of regional haze at Cape Romain is primary organic matter (POM) (14.4 pe rcent). While sulfates continue to be the contributor to visibility impairment, as indicate d in Figures 12 and 13, th e contributions of POM and elemental carbon (EC) are also of concern.

SC SIPR: Regional Haze Periodic Report (December 2012) 44Figure 12: Major Component Contribution on 20 Percent Best Days

0 10 20 30 40 50 60 7001/11/200602/07/200604/11/200607/04/200610/14/200612/13/200601/15/200702/05/200703/19/200709/12/200710/03/200712/26/200701/10/200804/09/200807/08/200810/09/200812/17/200801/10/200903/17/200905/16/200909/22/200911/15/200912/12/200901/23/201002/10/201003/18/201006/22/201009/26/201011/13/2010 Sea Salt

CM

Soil

EC

POM

Amm. NO3

Amm. SO4

Rayleigh

SC SIPR: Regional Haze Periodic Report (December 2012) 45Figure 13: Major Component Co ntribution on 20 Worst Days

0 50 100 150 200 250 300 350 40001/05/200604/02/200605/26/200606/28/200607/31/200609/26/200604/15/200705/30/200707/20/200708/16/200709/06/200711/14/200702/15/200803/28/200806/17/200807/26/200808/19/200809/30/200801/25/200903/14/200906/15/200907/03/200908/08/200909/28/200903/09/201005/02/201007/10/201009/02/201009/20/201012/04/2010 Sea Salt

CM

Soil

EC

POM

Amm. NO3

Amm. SO4

Rayleigh

To further examine these spikes in POM and EC, the Department conducted an analysis (Appendix A) to determine potential contributors. This analysis consisted of using HYSPLIT to conduct back trajectory analyses for the Cape Ro main monitoring site ( 45-019-0046) located in Charleston County on the five highest POM b ext days from 2006 to 2010. This analysis indicated that fires reported within and/or outside the state, have contri buted to the uncharacteristically high levels of POM.

40 CFR 51.308(g)(6): Assessment of Elements to Meeting RPG

40 CFR 51.308(g)(6), of the RHR requires an “ Assessment of whether the current implementation plan elements and strategies are su fficient to enable the st ate, or other states with Class I areas affected by emissions from that state, to meet all established reasonable progress goals.”

The Department believes the current implementation plan elements and strategies outlined in the original SC Regional Haze SIP are sufficient to enable South Carolin a and other neighboring
states to meet all the established RPGs. Please see the response provided for 40 CFR 51.308(g)(3): Assessment of Visibility Conditions.

SC SIPR: Regional Haze Periodic Report (December 2012) 46As outlined in Table 6 ( controls/reductions included in the original SC Regional Haze SIP) , the actual 2011 CAMD emissions of 66,131 tons of SO 2 are already below the 2018 projected emissions of 76,291 tons of SO 2 , with expected further decrease s. This information illustrates that SC as well as other neighbor ing states are on track to meet the established RPGs. Moreover,
these reductions are further elaborated on in th e emission reductions info rmation from Table 10 (installed controls and resulti ng reductions 2007-2011) and coupled with the further reductions listed in Table 11 (reductions not included in the 2018 Best and Final Inventory, detailed documentation in Appendix B). All together, this information demonstrates that the reduction of
SO 2 emissions will in fact be even greater than original anticipated, further demonstrating that the Department’s plan elements and strategies are sufficient to meet the established RPGs.

40 CFR 51.308(g)(7): Assessment of Monitoring Strategies

40 CFR 51.308(g)(7), of the RHR requi res, “A review of the state’ s visibility monitoring strategy and any modifications to the strategy as necessary.”

The primary monitoring network for the measurement and characterization of the contributors to regional haze, both nationwide and in South Ca rolina, is the IMPROVE network. Given that IMPROVE monitoring data from 2000-2004 serve as the baseline for the regional haze progress and tracking, the regional haze monitoring strategy must necessarily be based on, or directly comparable to, IMPROVE. The IMPROVE measur ements provide the only long-term record available for tracking visibility improvement or degradation and therefore South Carolina intends to rely on the continued availa bility of quality assured data collected through the IMPROVE network to comply with the regional haze monitoring requirement in the RHR.

T here is currently one IMPROVE site in South Carolina, representing the Cape Romain National Wildlife Refuge Class I Federal area (ROMA1). The State supplements the IMPROVE sampling by operating additional co-located monitoring. Additional monitoring at
C ape Romain includes:

 A Tapered Element Oscillating Micr obalance (TEOM) for continuously measuring PM 2.5 mass concentration;

 An Aethalometer for continuously measuring Black Carbon (BC);

 An integrating nephelometer, supported by South Carolina, for continuously measuring light scattering;

 Continuous monitoring of NO 2 and SO 2 precursor gasses; and

 Continuous monitoring of particulate Sulfate.

Two Optec NGN-2 Nephalometers have been tran sferred to South Carolina allowing operation and backup to minimize downtime required for m onitor maintenance or exchange. The operation and data reporting was supporte d in cooperation with VISTAS through 2009 South Carolina has continued to support the operati on of the Cape Romain nephelometer. SC performs field maintenance but uses the IMPROVE contractor (A RS) for instrument support, data management and reporting consistent with th e bulk of the IMPROVE Nephelom eter network. Availability of funding to continue contractor support is evaluated annually.

SC SIPR: Regional Haze Periodic Report (December 2012) 47Additional haze-related measuremen ts were made in South Carolina in 2002-2005 as part of special monitoring studies by the VISTAS regiona l planning organization. These studies were
intended to allow better understand ing of source contributions to PM 2.5 mass and visibility impairment. They included continuous monitoring of sulfate, nitrate, and carbon particulate to better understand daily variability in PM 2.5 and its components, detailed analyses of organic carbon collected on high volume filters to identify source contributions, and additional analyses of sodium and ammonium on IMPROVE filter samples. Funding is not available to continue these special studies; however, th e monitoring equipment has been transferred to the Department.

South Carolina has acquired seve ral continuous sulfate monitors and operates them at urban and
rural sites to further the understanding of bot h contributions to PM 2.5 mass and the related impact on visibility trends in South Carolina. The De partment is committed to continued operation of non-criteria monitors supporting re gional haze investigations wher e appropriate when support is
available.

In addition, the Department operates a PM 2.5 network of the filter based Federal Reference Method samplers, supported by continuous mass monitors (TEOMs), CSN (chemical speciation network) protocol filter base d speciated samplers and the co ntinuous particulate component (SO 4, BC) monitors descri bed above. These PM 2.5 measurements help the Department characterize particulate concentra tions across the state, and ther efore aid in the analysis of visibility impacts in a nd near the Class I areas.

The IMPROVE measurements are central to Sout h Carolina’s regional haze monitoring strategy, and it is difficult to visualize how the objectives listed a bove could be met without the monitoring and detailed sample analysis pr ovided through IMPROVE. Any reduction in the scope of the IMPROVE network in South Carolina and neighboring Class I Federal areas would jeopardize the State’s ability to demonstrate reas onable progress toward visibility improvement in its Class I areas and plan appr opriate activities to ensure future progress. In particular, South Carolina’s regional haze strategy relies on emissi on reductions that will re sult from the CAIR or
CSAPR and emissions reductions in neighboring States, whic h will occur on different time scales and will most likely not be spatially unifo rm. Continued monitoring at Cape Romain and representative Class I areas is important to document the air quality impacts of emissions
reductions. Because the current IMPROVE monitor at Cape Romain represents a unique Class I Federal area and a significant comp onent of the contributions at th at site are regional, reductions of the IMPROVE network that would impact the existing IMPROVE site or any of the nearest regional IMPROVE monitoring site s would eliminates South Carolina’s ability to track the progress or effectively plan improvements for th e Cape Romain Class 1 area. In the event the Cape Romain IMPROVE monitoring is proposed for elimination, S outh Carolina, in consultation with the EPA and relevant federal land managers (FLMs), will seek to develop an alternative approach for meeting the tracking obligation, pe rhaps by seeking contingency funding to carry out limited monitoring or by relyin g on data from nearby urban monitoring sites to demonstrate
trends in the reduction of concentrations of the contributors to visibility impairment. It is unlikely that alternative monitoring approaches w ill be sufficient to meet the South Carolina or RHR data requirements.

SC SIPR: Regional Haze Periodic Report (December 2012) 48Data produced by the IMPROVE monitoring network wi ll be used as the basis for preparation of the five-year progress reports and the ten-year SIP revisions, each of which relies on analysis of the preceding five years of da ta. Consequently, the monitoring data from the IMPROVE sites need to be readily accessible and as up to date as possible. Presumably, IMPROVE will continue to process information from its own measuremen ts at about the same pace and with the same attention to quality as it has shown in the recent past. The VIEWS web site ( http://views.cira.colostate.edu/web/ ) has been supported by VISTAS and the other RPOs to provide ready access to the IMPROVE data and data analysis tools. Therefor e, South Carolina is encouraging VISTAS and the other RPOs to mainta in support of VIEWS or an equivalent data management system to facilitate availability analysis of the IMPROVE and visibility related data. Based on these assumptions and analysis no modifications to the State’s visibility monitoring strategy are n ecessary at this time.

40 CFR 51.308(h): Recommendations for 5 Year Progress Report

40 CFR 51.308(h) or the RHR requires, “... At the same time the State is required to submit any 5-year progress report to EPA in accordance with paragraph (g) of this section, the State must also take one of the following actions based upon the information presented in the progress

report:

(1) ...provide to the Administrator a negative de claration that further revision of the existing implementation plan is not needed at this time;

(2) If the State determines that the implemen tation plan is or may be inadequate to ensure reasonable progress...the State must provide notifi cation to the Administrator and to the other States which participated in th e regional planning process...must also collaborate with the other States through the regional planning process fo r the purpose of developing additional strategies to address the plan’s deficiencies;

(3) ...the implementation plan is or may be inadequate ...due to emissions from sources in another county, the State shall provide notification, along with available information, to the Administrator; or

(4) Where the State determines that the implem entation plan is or may be inadequate to ensure reasonable progress due to emissions from sources within the State, the State shall revise its implementation plan to address the pl an’s deficiencies within one year.”

8. Conclusions

Based on the options above and the evidence pres ented here, the Department believes it is appropriate to subm it to the Administrator a ne gative declaration lett er specifying that no additional controls are necessary during this, the five-year pr ogress report (see SIP Amendment Cover Letter).

In keeping with the EPA’s recommendations relate d to consultation, the De partment enlisted the support of appropriate state, lo cal, and tribal air pollution cont rol agencies as well as the corresponding FLMs to formulate this report. As part of this commitment, the Department made an advanced, draft copy of this report available to the aforemen tioned agencies and sought their

SC SIPR: Regional Haze Periodic Report (December 2012) 49SC SIPR: Regional Haze Periodic Report (December 2012) 50 input. Comments received as part of this c onsultation can be found in Appendix D. Those comments seen as germane were taken into a ccount in developing th is progress report.

In addition, the Department also published a Notice of General Pub lic Interest in the South Carolina State Register , on October 26, 2012, providing a 30-day comment period along with a proposed public hearing on December 3, 2012, to inte rested parties (see Appendix C). Pursuant to 40 CFR 51.102 (2011), the Department did not r eceive a request for a h earing by the close of the comment period (November 26, 2012). Therefore, the Department cancelled the hearing. The Department received comments from EPA Region 4 staff during the public comment period and those comments have been addressed (see Appendix D).

The Department commits to continued consulta tion among the states and FLMs as it relates to any SIP revisions and/or the implementation of other programs having the potential to contribute to visibility impairment. The State anticipates that this will occur in much the same fashion as did the pre-hearing meetings, comments, a nd responses required by 40 CFR 51.308(i)(3).