Regional Haze State Implementation Plan 

Periodic Report 

South Carolina Class I Federal Areas 

Prepared by 

South Carolina Department of Health and Environmental Control 

Bureau of Air Quality 

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

EXECUTIVE SUMMARY 

The Clean Air Act (CAA) mandates requirements to protect visibility, especially in Class I 

Federal areas. In 1999, the US Environmental Protection 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 causes visibility impairment. These plans establish 

goals and emission reduction strategies based on trends from various sources including area 

source emissions, mobile source emissions (both 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 application of Best Available 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 requirements of 40 CFR 51.308(g) requiring periodic reports 

evaluating progress towards the RPGs. 

Ammonium sulfate is the largest contributor to visibility impairment at Cape Romain and 

reduction of sulfur dioxide (SO2) emissions is the most effective 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 SO2 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 committed 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), state 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 Regional Haze SIP submittal, 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. 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 more significant reductions in SO2 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 the Department of Health and Environmental Control (DHEC) submits 

a negative declaration to EPA specifying that its 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 Technology (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 Electric 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 SO2 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 SO2 Emission Reductions.................................................................................... 28 

5.1 EGU SO2 Emission Reductions and Utilization............................................................... 28 

5.2 Additional EGU SO2 Emission Reductions...................................................................... 31 

5.3 Unit Specific Point Source Reductions............................................................................. 33 
SC 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 

FIGURE 0-1: CLASS I FEDERAL AREAS AND THEIR CORRESPONDING AREA OF INFLUENCE.............. 9 

TABLE 1: SOUTH CAROLINA EMISSION UNITS AFFECTING CLASS I FEDERAL AREAS IN GEORGIA 10 

TABLE 2: SOUTH CAROLINA EMISSION UNITS AFFECTING CLASS I FEDERAL AREAS IN NORTH 

CAROLINA.............................................................................................................................. 11 

TABLE 3: MACT SOURCE CATEGORIES WITH COMPLIANCE DATES ON OR AFTER 2002 ................ 13 

TABLE 4: ICI BOILER MACT REDUCTIONS COMPARED TO THE 2009 AND 2018 VISTAS

INVENTORY............................................................................................................................ 15 

TABLE 5: COMPARISON OF CAIR & CSAPR SO2 EMISSION LIMITS VS. 2011 ACTUAL EMISSIONS 18 

TABLE 6: SC COAL FIRED POWER PLANTS: EXISTING AND FUTURE EXPECTED CONTROLS AND 

EMISSION REDUCTION STRATEGIES ....................................................................................... 21 

FIGURE 2: SUBJECT-TO-BART FACILITIES AND PROXIMITY TO CAPE ROMAIN WILDERNESS 

AREA ..................................................................................................................................... 23 

TABLE 7: SOUTH CAROLINA BART DETERMINATIONS.................................................................. 24 

TABLE 8: CTGS PROMULGATED IN 2006, 2007, AND 2008 ............................................................ 28 

FIGURE 3: SOUTH CAROLINA ACID RAIN PROGRAM UNIT EMISSIONS AND HEAT INPUT DATA ..... 29 

FIGURE 4: VISTAS ACID RAIN PROGRAM UNIT EMISSIONS AND HEAT INPUT DATA.................... 30 

TABLE 9: COMPARISON OF ACID RAIN PROGRAM DATA FOR 2002, 2009, 2010, AND 2011........... 31 

FIGURE 5: SOUTH CAROLINA SO2 EMISSION REDUCTIONS ............................................................ 32 

FIGURE 6: SCE&G NETWORK SO2 EMISSION REDUCTIONS .......................................................... 33 

TABLE 10: SUMMARY OF SOUTH CAROLINA EGU SO2CONTROLS BETWEEN 2007 AND 2011....... 34 

TABLE 11: UNIT SPECIFIC REDUCTIONS NOT INCLUDED IN THE 2018 BEST AND FINAL 

INVENTORY............................................................................................................................ 35 

TABLE 12: REASONABLE PROGRESS GOALS FOR SC...................................................................... 36 

FIGURE 7: RATE OF PROGRESS GLIDEPATH FOR 20% BEST DAYS AT CAPE ROMAIN, SC .............. 38 

FIGURE 8: RATE OF PROGRESS GLIDEPATH FOR 20% WORST DAYS AT CAPE ROMAIN, SC........... 39 

FIGURE 9: RATE OF PROGRESS GLIDEPATH FOR 20% WORST DAYS AT CAPE ROMAIN, SC........... 40 

FIGURE 10: RATE OF PROGRESS GLIDEPATH FOR 20% BEST DAYS AT CAPE ROMAIN, SC ............ 41 

TABLE 13: SOUTH CAROLINA 2018 BASEG4 EMISSIONS INVENTORY BY SOURCE SECTOR ........... 42 

TABLE 14: SOUTH CAROLINA 2007 EMISSIONS INVENTORY BY SOURCE SECTOR.......................... 43 

TABLE 15: SOUTH CAROLINA 2002 ACTUAL EMISSIONS INVENTORY BY SOURCE SECTOR ........... 43 
SC SIPR: Regional Haze Periodic Report (December 2012) 6 

FIGURE 11: 5-YEAR EXTINCTION FOR THE MAJOR COMPONENTS OF REGIONAL HAZE AT CAPE 

ROMAIN ................................................................................................................................. 44 

FIGURE 12: MAJOR COMPONENT CONTRIBUTION ON 20 PERCENT BEST DAYS.............................. 45 

FIGURE 13: MAJOR COMPONENT CONTRIBUTION ON 20 WORST DAYS ......................................... 46 

 

Appendices 

Appendix A: Back Trajectory Analysis of Beta Extinction 

Appendix B: Point Source SO2 Emissions Reductions 

Appendix C: Notice of General Public Interest 

Appendix D: Written Comments 

Appendix E: Copy of Legal Authority 
SC SIPR: Regional Haze Periodic Report (December 2012) 7 

 

Regional Haze Five-Year Progress Report Review Requirements 

Introduction 

The Clean Air Act (CAA) mandates requirements to protect visibility, especially in Class I 

Federal areas. In 1999, the US Environmental Protection 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 causes visibility impairment. These plans establish 

goals and emission reduction strategies based on trends from various sources including area 

source emissions, mobile source emissions (both on-road and non-road emissions), biogenic 

emissions, and wildfire and agriculture emissions. 

These SIPs were developed to reduce 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 (RPOs) 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 making “reasonable progress” toward eliminating all 

manmade visibility impairment from mandatory Class I areas. With the help of the Visibility 

Improvement - State and Tribal Association of the Southeast (VISTAS) RPO, South Carolina has 

developed a SIP to address visibility 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 Carolina 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 provided in its SIP, for the 20 percent worst days, 

South Carolina has adopted a RPG of a 3.8 deciview (dv) reduction in visibility 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, 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. 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 update to the State’s RPGs as a revision to the 

SC Regional Haze SIP. The aforementioned predicted 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 established 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 focus 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 states to submit a comprehensive SIP revision 

in 2018 and every 10 years thereafter. Section 51.308(g) requires progress reports for each Class 

I area in the state in the form of SIP revisions every 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 within the State.” 

Figure 1 illustrates the Class I Federal area located within South Carolina along with its area of 

influence (AOI) as well as the Class 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 Evaluation) 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 that 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 compliance, 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 development process, both Georgia and North 

Carolina submitted letters to South Carolina requesting 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 North 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 Carolina’s Class I Federal Area(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 factor analysis, the results of which indicated 
that none of the evaluated options were economically feasible (see Appendix N of the SC 

Regional Haze SIP). 

Table 1: South Carolina Emission Units Affecting 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 

MeadWestvaco 2,315 2,706 OKEF – 297 

(Kapstone) 

006 

0.008 2,315 2,706 WOLF - 213 

ESP 

(1984 + 1977) 

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

0.017 6,214 5,203 WOLF – 201 

ESP 

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

0.016 6,585 5,144 WOLF - 201 

ESP 

Note: Sources in Bold are subject to CAIR. Tables 6, 10, and 11 provide information on the 

status of the controls for those sources subject to CAIR. 

Table 2 defines the emission units at the point sources in South Carolina that were found to 

contribute to visibility at the North Carolina Class I Federal Areas. 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) 10 
Table 2: South Carolina Emission Units Affecting Class I Federal Areas in North Carolina 

Note: Sources in Bold are subject to CAIR. Tables 6, 10, and 11 provide information on the 

status of the controls for those sources subject to CAIR. 

Past/Projected 

Emissions (tpy) 

South Carolina 

Facility 

Sources Relative 

Contribution 

2002 2018 

Distance (km) 

to Class 1 

Areas 

Existing Controls 

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

0.012 2,386 4,347 JOKI - 165 

ESP 

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

0.011 2,643 4,140 JOKI - 165 

ESP 

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

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): Status of Measures in SIP 

40 CFR 51.308(g)(1), requires “A description of the status of implementation of all measures 

included in the implementation plan for achieving 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 measure. 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 and 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 these measures were not included in future year 

inventories. Emission reductions from these measures 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) 11 
SC SIPR: Regional Haze Periodic Report (December 2012) 12 

1. Federal Programs 

The emission reductions associated with the federal 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 where delays or modification have altered emissions 

reduction estimates such that the original estimates of emissions are no longer accurate, 

information is also provided on the effects of these alterations. 

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

In this regulation, EPA set a particulate matter (PM) emissions standard for new heavy-duty 

engines of 0.01 g/bhp-hr, which took full effect for diesel engines in the 2007 model year. This 

rule also included standards for oxides of nitrogen (NOX) and non-methane hydrocarbons 

(NMHC) of 0.20 g/bhp-hr and 0.14 g/bhp-hr, respectively. These diesel engine NOX and NMHC 

standards were successfully phased in together 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 EPA required a 97 percent reduction in the sulfur content of 

highway diesel fuel -- from levels of 500 ppm (low sulfur diesel) 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 averaging program for on-road vehicles, modeled after the California 

LEV ( Low Emissions Vehicle) II standards, became effective in the 2005 model year. The Tier 

2 program allows manufacturers to produce vehicles with emissions ranging from relatively dirty 

to very clean, but the mix of vehicles a manufacturer sells each year must have average NOX

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 emissions of NOX, hydrocarbons, and carbon monoxide (CO) 

from several groups of nonroad engines, including industrial spark-ignition engines and 

recreational nonroad vehicles. Industrial spark-ignition engines power commercial and industrial 

applications and include forklifts, electric generators, airport baggage transport vehicles, and a 

variety of farm and construction applications. 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 standards 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. The 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 Technology (MACT) Programs (40 CFR Part 63) 

VISTAS applied controls to future year emissions estimates from various MACT regulations for 

volatile organic compounds (VOC), SO2, NOX, and PM on source categories where controls 

were installed on or after 2002. (Requirements to reduce toxic air emissions under these 

regulations also have the co benefit of reducing VOC and other criteria pollutant emissions.) 

Control estimates are documented in the report entitled, “Control Packet Development and Data 

Sources,” Alpine Geophysics, July 14, 2004. Table 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 Kraft, 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, SO2 

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, SO2 
SC 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 SO2

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

Reciprocating Internal Combustion Engines ZZZZ 6/15/04 6/15/07 NOX, 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 (ICI) 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, VISTAS chose to leave the emissions reductions 

associated with this regulation in place since the CAA required use of alternative control 

methodologies under Section 112(j) for uncontrolled source categories. The applied MACT 

control efficiencies were 4 percent for SO2 and 40 percent for course particulate matter (PM10) 

and fine particulate matter (PM2.5) to account for the co-benefit from 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 affected the VISTAS future year 

inventories, VISTAS created an analysis of inventory data to determine the level of SO2, PM10, 

and PM2.5 reductions associated with the vacated regulation. Table 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 those 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 Compared 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 PM10, tpy -13,325 -14,556 211,267 248,367 4,161,695 4,549,680

Primary PM2.5, tpy -10,892 -11,919 157,615 185,490 1,124,150 1,195,487

SO2, tpy -7,773 -8,188 548,196 575,716 3,468,899 2,169,773

(1)ICI Boiler MACT reduction 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-Revision 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 vacated 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 SO2, and 7,000 tpy of VOCs. 

However, in March of 2011, the EPA published a notice stating their intention to reconsider 

certain aspects of the boiler and commercial and 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 will 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 the reconsideration has not been finalized. 

1.5 Federal Consent Agreements

The VISTAS 2009 and 2018 emissions inventories took 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, Southern 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 SO2 annually. The sulfuric acid plant emitted 1,145 tons of SO2 in 2002. In 

2009, the year in which controls were applied, the plant emitted 379 tons of SO2, and in 

2010 the plant emitted 42 tons of SO2. 

 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 SO2 emissions from the #8 Power Boiler with a wet 

scrubber. This device was installed and operational in October of 2007. Emissions of SO2

from the facility during 2002 were 4,575 tpy. Emissions of SO2 from the facility during 
SC SIPR: Regional Haze Periodic Report (December 2012) 16 

2009, after installation of the scrubber, were 1,009 tpy. Emissions of SO2 in 2010 from 

the facility were 1,252 tpy. 

 Santee Cooper (US District Court, South Carolina Charleston Division): Santee Cooper is 

a quasi-public South Carolina utility that operates 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 power plants and two proposed new coal-fired 

units. Specifically, the settlement requires Santee Cooper to install state-of-the-art air 

pollution controls on certain units and upgrade other existing air pollution controls. The 

controls will result in the removal of approximately 37,500 tons per year of SO2 and 

29,500 tons per year of NOX from Santee Cooper’s existing coal-fired units. The 

settlement also requires Santee Cooper to retire excess SO2 emission allowances from its 

Acid Rain allocations and restrict trade of its NOX allowances. The coal-fired power 

plants and their locations in South Carolina covered under this settlement include: Cross 

Plant located in Pineville, Berkeley County, 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 located 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-fired 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 its Camden, South Carolina facility such 

that two of its boilers will comply with a combined NOX emissions limit of 202 tons on a 

12-month rolling average basis by converting one boiler to natural gas controlled with 

SCR technology, and installing Mobotec with Rotamix designed to reduce NOX

emissions by 65 percent on an additional boiler. SO2 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 threshold established.) Information regarding 

this consent decree was not included in the State’s Regional Haze SIP (as it postdates the 

submittal), however, this information is being offered as qualitative evidence that further 

reductions are being realized. Appropriate updated information will be offered in the 

State’s next required SIP revision. 

 Lafarge (US District Court, Southern District of 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 SO2 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. Appropriate updated information will be offered in the State’s next 

required SIP revision. 

2. EGU Control Strategies 

Emissions from EGUs have been regulated through a number of mechanisms, including CAIR; 

the Cross State Air Pollution Rule (CSAPR); State programs; federal consent agreements; and 

various source-specific permitting actions. Reductions associated with many of these 

mechanisms were used to estimate the 2018 visibility improvements at the VISTAS Class I 

areas. Since development of the Best and Final inventory, 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 Assembly enacted the Clean Smokestacks Bill, 

which required significant actual emissions reductions from coal-fired power plants in North 

Carolina. These reductions were included as part of the VISTAS 2018 Best and Final modeling 

effort. Under the act, power plants were required to reduce their NOX emissions by 77 percent in 

2009 and their SO2 emission by 73 percent in 2013. Actions taken to date by facilities subject to 

these requirements comply with the provisions of the Clean Smokestacks 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 SO2 and less than the 2009 system annual cap of 

56,000 tons of NOX. 

2.2 Georgia Multi-Pollutant Control for Electric Utility Steam 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 regulation were included as part of the VISTAS 2018 

Best and Final modeling effort. These controls will reduce SO2 emissions from the affected 

emissions units by at least 95 percent and will reduce NOX 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 regulations became effective on July 16, 2007, and required reductions in 

NOX, SO2, 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 NOX emission by 

almost 70 percent and SO2 emission by 80 percent. The second phase of emissions controls 

occurs in the 2012/2013 time frame. At full implementation, the HAA will reduce NOX

emissions by approximately 75 percent from 2002 levels and SO2 emissions by approximately 85 

percent from 2002 levels. Maryland is not a VISTAS participant. However, Maryland borders 

two VISTAS states, and Maryland facilities have 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 timely 
SC SIPR: Regional Haze Periodic Report (December 2012) 18 

manner. Reductions associated with this program 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 EPA promulgated CAIR, which required reductions in emissions of NOX

and SO2 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 petitions for review of CAIR and CAIR Federal 

Implementation Plans, including their provisions establishing the CAIR NOX annual and ozone 

season and SO2 trading programs. On July 11, 2008, the Court issued an opinion vacating and 

remanding these rules. However, parties to the litigation requested rehearing 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 CAIR 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 NOX 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 SO2 annually and 1,400,000 tons of NOX annually in covered states. 

These estimates represent a 71 percent reduction in SO2 and a 52 percent reduction in NOX 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 vacated CSAPR. CAIR remains in effect while 

EPA develops a replacement rule. South Carolina’s CAIR regulations, at SC Regulation 61-

62.96, went into effect on May 1, 2009, replacing the NOX SIP Call Program. Sources within the 

State are continuing to comply with CAIR. 

Table 5 provides a comparison of the emission budgets under the various programs aimed at 

reducing transport emission in South Carolina. While the budget numbers associated with CAIR 

represent a trading component and not a state-wide limit as was intended with CSAPR, both the 

emission limits and the 2011 actual emissions are adequate to demonstrate that South Carolina is 

on track to meet its RHR RPGs. 

Table 5: Comparison of CAIR & CSAPR SO2 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 38,348 
SC SIPR: Regional Haze Periodic Report (December 2012) 19 

Annual

NOx Ozone 

Season

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

SO2 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 consent agreements with major utilities contained remedies that imposed control 

requirements or other reductions in future year emissions. These requirements were taken into 

account in the VISTAS 2018 Best and Final inventory. 

 Under a settlement agreement, Tampa Electric installed permanent emissions control 

equipment by 2008 to meet stringent pollution limits; implemented a series of interim 

pollution-reduction measures to reduce emissions 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 NOX, SO2, and PM. 

 In the VEPCO (Dominion Power) consent agreement, the utility agreed to spend $1.2 

billion by 2013 to eliminate 237,000 tons of SO2 and NOX 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 NOX emission rates by 

61 percent at its Crist generating plant by 2007. 

 American Electric Power agreed to spend $4.6 billion dollars to eliminate 72,000 tons of 

NOX emission annually by 2016 and 174,000 tons of SO2 emissions annually by 2018 

from sixteen plants located in Indiana, Kentucky, Ohio, Virginia, and West Virginia. 

2.6 Specific EGU Estimates and Reductions 

Table 6 lists all EGU units in South Carolina having a calculated visibility impact 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 the units in 2018 as part of the Best and Final 

modeling effort, the current status of those control assignments, estimated tons of SO2 emissions 

reduced (2009-2002), and actual 2011 emissions from those units, where available from the 

Clean Air Markets Division (CAMD). 

This source sector has been shown to be a major contributor to visibility impairment in the 

VISTAS Class I areas, including Cape Romain. Good progress has been made towards reducing 

SO2 emissions from this sector. Additional reductions 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 federal programs and one federal consent agreement will provide further reductions in SO2

from this source sector, either as a result of SO2 requirements or as co-benefit from the reduction 

of HAPS. These benefits were not considered in the development of the VISTAS Best and Final 
SC SIPR: Regional Haze Periodic Report (December 2012) 20 

 

2018 inventories. Any additional SO2 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 December 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 SO2

emissions by 41 percent beyond the reductions expected from CSAPR. These reductions are 

expected in the 2016 time frame. 

2.7.2 2010 SO2 National Ambient Air Quality Standard (NAAQS) 

On June 2, 2010, the EPA strengthened the primary NAAQS for SO2 by revising the primary 

SO2 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, facilities with significant emissions of SO2, many of which 

are EGUs, will be required to demonstrate compliance with the standard no later than 2017. 

Pursuant to the CAA, states are required to submit such demonstrations 18 months from the date 

of designation of a nonattainment area. The current schedule for the finalization of nonattainment 

areas for SO2 is June 2013.2

2.7.3 Tennessee Valley Authority Federal Consent Agreement 

In April of 2011, the EPA announced a settlement with the Tennessee Valley Authority (TVA) to 

resolve alleged CAA violations at 11 of its coal fired plants in Alabama, Kentucky, and 

Tennessee. The settlement requires TVA to invest $3 billion to $5 billion on new and upgraded 

state-of-the-art pollution controls. Once fully implemented, the pollution controls and other 

required actions will address 92 percent of TVA’s coal-fired power plant capacity, reducing 

emissions of NOX by 69 percent and SO2 by 67 percent from TVA’s 2008 emissions levels. We 

expect Tennessee’s Department of Environment & Conservation to provide the specifics of 

TVA’s emission reductions from this agreement as part of their first five-year 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) 21 

Table 6: SC Coal Fired Power Plants: Existing and Future Expected Controls and Emission Reduction Str

Facility Emission 

Unit 

2002 Base 

Year 

Emissions 

Tons per 

year (tpy) 

2009 

VISTAS 

Emissions 

(tpy) 

Estimated Tons 

Reduced 

(2002 minus 

2009) 

(tpy) 

Actual 

Emission 

(2011 

CAMD) 

(tpy) 

2018 

Projected 

Emissions 

(tpy) 

SO2

Emission 

Control 

Included 

in SIP 

Projecte

d 

Control 

Date in 

SIP 

001 2386 5125 -2739 1251 4347 None N/A 002 2643 4881 -2238 1348 4140 None N/A 

Duke Energy: W.S. 

Lee 

(0200-0004) 003 4384 5666 -3574 3159 7274 None N/A 

Progress Energy: 

Robinson 

(0820-0002) 

001 8754 7784 970 4514 7087 None N/A 

001 3947 719 3228 2179 719 Scrubber 2003 

(1995) 

002 10260 3380 6880 3771 3380 Scrubber 2003 

(1984) 

3 3835 N/A 1647 3835 Scrubber 2006 

Santee Cooper: 

Cross 

(0420-0030) 

4 3835 N/A 1566 N/A Scrubber 2008 

Santee Cooper: 001 5399 4075 1324 1535 None N/A 

Grainger 

(1340-0003) 

002 4949 4088 861 1524 None N/A 

001 240 None N/A 6 N/A None N/A 002 83 None N/A 6 N/A None N/A 003 11315 7677 3638 3189 6761 None N/A 

Santee Cooper: 

Jefferies 

(0420-0003) 

004 11789 7259 4530 3308 6609 None N/A 

001 18181 1842 16339 275 681 Scrubber 2003 002 10298 1842 8456 348 681 Scrubber 2003 003 4971 684 4287 1895 684 Scrubber 2003 

Santee Cooper: 

Winyah 

(1140-0005) 

004 3620 689 2931 992 689 Scrubber 2006 

001 6214 5715 499 3844 5203 None N/A 002 6585 5649 936 4588 5144 None N/A 

SCE&G: Canadys 

(0740-0002) 

003 7924 829 7095 7200 757 None N/A 
Facility Emission 

Unit 

2002 Base 

Year 

Emissions 

Tons per 

year (tpy) 

2009 

VISTAS 

Emissions 

(tpy) 

Estimated Tons 

Reduced 

(2002 minus 

2009) 

(tpy) 

Actual 

Emission 

(2011 

CAMD) 

(tpy) 

2018 

Projected 

Emissions 

(tpy) 

SO2

Emission 

Control 

Included 

in SIP 

Projecte 

d 

Control 

Date in 

SIP 

SCE&G: Cope 

(1860-0044) 

001 1712 1489 223 1575 1087 Scrubber 1996 

001 5468 5409 59 3501 4944 None N/A 

SCE&G: McMeekin 

(1560-0003) 

002 6401 5400 1001 3717 4936 None N/A 

SCE&G: Urquhart 

(0080-0011) 

3 5695 4506 1189 4703 3676 None N/A 

001 18803 1710 17093 1904 1502 Scrubber N/A 

SCE&G: Wateree 

(1900-0013) 

002 18207 1741 16466 1979 875 Scrubber N/A 

SCE&G: Williams 

(0420-0006) 

001 22698 25457 -2759 607 1280 Scrubber 2002 

Total 202926 121286 66131 76291 

*Notations for Baghouses were not included in SC Regional Haze SIP based on the Department’s decision to Emission 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) 22 
3. Review of BART Determinations 

The VISTAS Best and Final 2018 emissions inventories contained emissions reductions 

expected to be achieved from BART determinations made by the member States. Figure 2 shows 

the 200 km radius around the Cape Romain Wilderness Area. This figure also depicts the 

facilities in nearby states containing units that are subject-to-BART. 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 determinations made in South Carolina. More information on these 

analyses and determinations may be found in Chapter 7 (7.8) of the SC Regional Haze SIP. As 

outlined in Appendices H.4, H.5, and H.6 BART modeling sensitivities indicate that no 

additional controls were needed during this control period. 

SC SIPR: Regional Haze Periodic Report (December 2012) 23 
3.2 North Carolina

Two facilities located in North Carolina were subject to BART, Blue Ridge Paper in Canton, 

North Carolina and PCS Phosphate in Aurora, North 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 Romain’s AOI in Georgia were subject to BART, 

International Paper, Savannah, Georgia, and International 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 subject 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 Class I Areas, December 17, 2007, page iii. 

SC SIPR: Regional Haze Periodic Report (December 2012) 24 
 Facility 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 refined modeling technique – Appendix O from SC Regional Haze SIP 

** MeadWestvaco (Kapstone) also accepted limits in the Title V permit renewal to limit SO2 emissions 

SC SIPR: Regional Haze Periodic Report (December 2012) 25 
SC SIPR: Regional Haze Periodic Report (December 2012) 26 

 

4.0 Reasonable Progress Determinations 

Regional air quality modeling projected that reductions in SO2 from EGU and non-EGU point 

sources would result in the greatest improvements in visibility at VISTAS Class I areas. 

Therefore, for this first round of regional haze planning, VISTAS chose to focus reasonable 

progress evaluations on potential SO2 emission controls from these source sectors. To select the 

specific point sources that would be considered for each Class I area, states first identified the 

geographic areas that most likely influenced visibility in each Class I area and then identified the 

major SO2 point sources in that geographic area. VISTAS created detailed spreadsheets 

identifying SO2 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 regulations, provided data on emission sources, potential pollution 

control measures, emission reductions, and the costs of implementing those controls. Every 

available SO2 control strategy in AirControlNET was run against the EGU and non-EGU point 

source inventories to develop a master list of available, increment control strategies for VISTAS 

states to use in reasonable progress controls development. States reviewed stacks with an 

estimated calculated sulfate visibility contribution of at least 1 percent to any Class I area to 

determine if further SO2 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 having the opportunity for cost-effective control 

installation were asked to submit a reasonable progress four factor analysis. More detail on the 

methodology of the VISTAS reasonable progress analysis may be found in Appendix H of South 

Carolina’s Regional Haze SIP. 

After review of all data, South Carolina determined that no sources required further analysis to 

satisfy reasonable progress requirements during the first round of regional haze planning. 

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

Since development of the 2018 Best and Final inventory 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 March 26, 2010, the International Maritime Organization officially designated waters off 

North American coasts as an area in which stringent 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 expects emissions from ships operating in the 

designated area to be reduced by 320,000 tons for NOX, 90,000 tons for PM2.5, and 920,000 tons 

for SO2, which is 23 percent, 74 percent, and 86 percent, respectively, below predicted levels in 

2020 absent the Emissions Control Area designation. 

Implementation of the Emission Control Area means that ships entering the designated area 

would need to use compliant fuel for the duration of their voyage that is within that area, 

including time in port as well as voyages whose 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, NOX after-treatment requirements become applicable. 

4.3 Residual Risk Requirements 

The CAA requires the EPA to assess the risk remaining after application of final technologybased air toxics standards to any source category within 8 years of setting 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 health and protect against adverse environmental effects. Final rules 

for this CAA requirement are expected for 28 source categories between 2011 and 2013. 

Additional requirements to reduce toxic air emissions under the residual risk assessment may 

also have co benefits for the reduction of VOC and other criteria pollutant emissions between 

now and 2018. 

4.4 Control Technique Guidelines 

The federal CAA (§ 172(c)(1)) provides that SIPs for nonattainment areas must include 

reasonably available control techniques (RACT) for 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 RACT for sources of VOC emissions covered by a 

control techniques guidelines document (CTG). Section 183(e) then directs the EPA to list for 

regulation those categories of products that account for at least 80 percent of the VOC emissions 

from commercial products in ozone nonattainment areas. 

RACT controls for source categories controlled by a CTG are known as CTG RACTs. CTG 

RACTs have been issued for various printing, coating, and cleaning operations. In 2006, 2007, 

and 2008, the EPA published CTGs as listed in Table 8. 

South Carolina provided an analysis of these sources for the state’s single nonattainment area 

(the York County portion of the Rock Hill-Fort Mill Area Transportation Study (RFATS) 

Metropolitan Planning Organization (MPO) as part of the Charlotte-Gastonia-Rock Hill, North 

Carolina-South Carolina (Metrolina) nonattainment area). This certification included negative 

declarations for certain source categories, meaning that the Department concluded that no such 

sources are located in the York County portion of the Metrolina nonattainment area. The EPA 

evaluated the proposed revisions to South Carolina’s SIP, and concluded that they are consistent 

with statutory and regulatory requirements and EPA guidance. As a result, on November 28, 

SC SIPR: Regional Haze Periodic Report (December 2012) 27 
2011, 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 emissions reductions achieved 

throughout the State through implementation of the measures in paragraph (g)(1).”

5. Overall SO2 Emission Reductions 

As in the original SIP submittal, this periodic update is focused on the largest contributor to 

visibility impairment, sulfates. Overall SO2 emissions have decreased in South Carolina. 

5.1 EGU SO2 Emission Reductions and Utilization 

The large reductions in SO2 emissions from electric generating units during 2009 resulted from 

many factors, including control installations, units switching to cleaner fuels, load shifting from 

dirtier units to cleaner units, and an overall decrease in demand for generation. CAMD data for 

Acid Rain Program units from 2002 through 2011 indicate that reductions in SO2 emissions 

appear to be maintained, and further reductions achieved, even though heat input to these units 

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

VISTAS. 

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

(source: USEPA CAMD Database)

Figure 3 depicts the trends for South Carolina’s Acid Rain Program units that report annual 

emissions to CAMD. Between 2002 and 2011, heat input to these units actually increased from 

approximately 418,577,515 mmbtu to 443,900,798 mmbtu. However, actual SO2 emissions from 

these units decreased from 199,118 tons annually in 2002 to 66,166 tons annually in 2011, a 

decrease of 67 percent, and the average SO2 emission rate from these units decreased from 0.951 

lbs SO2/mmbtu in 2002 to 0.298 lbs SO2/mmbtu in 2011, a decrease of 69 percent. The 

reductions in emissions demonstrate that even with an increase in demand for power, as evinced 

by the increased heat input to these units; a significant reduction to overall SO2 emissions 

occurred due to the installation of controls and the use of cleaner burning fuels. 

A comparison of 2009 and 2011 data for South Carolina shows similar results. Emissions fell 

from 93,941 tons of SO2 in 2009 to 66,166 tons of SO2 in 2011, and the emissions rate dropped 

from 0.459 lbs SO2/mmbtu to 0.298 lbs SO2/mmbtu. The overall South Carolina emission rate is 

expected to continue to drop in 2012 due to the start up of additional scrubbing capacity and to 

SC SIPR: Regional Haze Periodic Report (December 2012) 29 
fuel switches. (CAMD heat input data for South Carolina dropped only slightly for 2011, to 

444,000,000 mmbtu, indicating SO2 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. SO2 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 

SO2 emission rate from these units decreased from 0.971 lbs SO2/mmbtu in 2002 to 0.318 lbs 

SO2/mmbtu in 2011, a decrease of 67.3 percent. As additional 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 units from 1,619,348 tons of SO2 in 2009 to 1,166,572 tons of SO2 in 

2011, and the emission rates of SO2 fell from 0.465 lbs/mmbtu to 0.318 lbs/mmbtu. 

Since sulfates have been shown to be the predominant species of concern to visibility impairment 

at Cape Romain during the first round of regional haze planning, visibility improvements from 

SC SIPR: Regional Haze Periodic Report (December 2012) 30 
reduced sulfate contribution should 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 

SO2 Emissions 

tons/year 

SO2 Rate 

lbs/mmbtu 

Heat Input 

mmbtu/hr 

SO2 Emissions 

tons/year 

SO2 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 SO2 Emission Reductions 

Moreover, as depicted in Figure 5, SC had 2007 SO2 emissions that were well above the 2009 

modeled values. This reduction occurred because several sources did not have controls installed 

until after the initial SC Regional Haze SIPs 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) 31 
Figure 5: South Carolina SO2 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 2018G4

Emissions (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 Carolina have seen marked decreases in SO2 emissions 

over the last several years. An analysis of South Carolina Electric & Gas (SCE&G) facilities in 

the state indicates that SO2 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 recently announced, as part of the annual Integrated 

Resource Plan filed with the Public Service Commission of South Carolina, its plans to retire up 

to six coal-fired generating units at three locations 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/current-news-releases/sceg-announces-plans-to-retire-a-portion-of-its-coalfired-generation.htm, last visited October 25, 2012). 

SC SIPR: Regional Haze Periodic Report (December 2012) 32 
Figure 6: SCE&G Network SO2 Emission Reductions 

SCE&G Network of PC-Fired Facilities

0

20,000

40,000

60,000

80,000

100,000

120,000

19971998199920002001200220032004200520062007200820092010

Year

SO2 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 EGUs installed additional SO2 controls after 2007. 

For example, as noted, scrubbers were installed at SCE&G Williams unit 001 and Wateree units 

001 and 002 in 2010, resulting in significant additional SO2 emission reductions not accounted 

for in the original VISTAS modeling scenarios. As the table indicates, emissions have steadily 

decreased due to these controls; a decrease from 73,679 in 2007 to just 13,897 in 2011. 

SC SIPR: Regional Haze Periodic Report (December 2012) 33 
Table 10: Summary of South Carolina EGU SO2 Controls between 2007 and 2011 

Facility Emissions 

Unit 

Emission 

Controls 

Projected 

Control 

Date in SIP 

2007 SO2

Emissions 

(TPY) 

2009 SO2

Emissions 

(TPY) 

2011 SO2

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 

SCE&G: Wateree 001 Scrubber 2010 15076 1,710 1904 

(1900-0013) 002 Scrubber 2010 15863 1,741 1979 

McMeekin 001 Low Sulfur Coal 06/2011 6139 5,409 3501 

(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 additional point source reductions based on planned or 

already announced retirements and conversion to natural gas. 

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

Facility Emissions 

Unit 

Emission 

Control 

Estimated 

SO2 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 

Santee Cooper: 001 None 1535 N/A Expected to be retired by 2018 

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) 35 
The additional reductions (marked by 60,065 tons/year of SO2 emissions based on 2011 CAMD 

emissions) will further help to ensure that Cape Romain will achieve the RPGs for visibility 

improvement by 2018. 

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

40 CFR 51.308(g)(3) of the RHR requires, “For each Class I area in the state, an assessment of 

the following visibility conditions and changes, with values for 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 visibility 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 States to establish RPGs (in dv) for each 

Class I Federal area within 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 condition 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 emissions 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 inventory known as BaseG4 was made available 

in 2008. The result of this change to the inventory led to slight change 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) 36 
6.1 Visibility Conditions 

An analysis of emission reductions in South Carolina 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 conditions, the difference between current visibility 

and baseline visibility, and a five-year rolling average for the most (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 demonstrate visibility on the 20 percent 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 SO2 emissions based on further controls, shutdowns, and 

conversions to either natural gas or lower sulfur fuels (see Appendix B and Tables 10 and 11) 

will serve to continue this downward trend in the coming years. 

In addition to improvement in visibility on the 20 percent best visibility 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 last 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 the Interagency Monitoring of Protected Visual 

Environments (IMPROVE) network and taken from Attachment G (Supplemental Analysis for 

Chapter 9).6

 Specifically, the figure shows baseline (2000-2004) and period 1 (2005-2009) 20 

percent worst and 20 percent best visibility estimates and natural condition targets for tracking 

progress under the RHR for Cape Romain. 

As discussed in the SC Regional Haze SIP, the greatest benefits on the 20 percent worst days for 

Cape Romain were projected to result from further reducing SO2 from EGUs. As outlined in 

Section 5, the reductions from SO2 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 Haze SIP to re-examine the need for additional 

non-EGU controls during this, the state’s five-year progress report. However, as evidenced by 

the current and future SO2 emission reductions from EGUs, further 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) 37 
SC SIPR: Regional Haze Periodic Report (December 2012) 38 

14.29 14.29 14.29

13.16 12.76

0 5 

10 15 20 25 30 35 

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 

Haziness Index (Deciviews)

Year

Reasonable Progress Assessment Base G2 inventor

new IMPROVE Algorithm

Cape Romain - Best 20% Days

Baseline Natural Condition (20% Best Days) Observation Method 1 Prediction 

Figure 7: Rate of Progress Glidepath for 20% Best Days at Cape Romain, SC 
Figure 8: Rate of Progress Glidepath for 20% Worst Days at Cape Romain, SC 

25.28

23.12

20.73

18.33

15.94

13.54

26.48

24.46

22.65

0 5 

10 15 20 25 30 35 

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 20

Haziness Index (Deciviews)

Year

Uniform Rate of Reasonable Progress Glide Path

Cape Romain - W20% Data Days

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction Rolling Av

SC SIPR: Regional Haze Periodic Report (December 2012) 39 
Figure 9: Rate of Progress Glidepath for 20% Worst Days at Cape Romain, SC 

SC SIPR: Regional Haze Periodic Report (December 2012) 40 
Figure 10: Rate of Progress Glidepath for 20% Best Days at Cape Romain, SC 

SC SIPR: Regional Haze Periodic Report (December 2012) 41 
SC 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 impairment from all sources and 

activities within the state. Emissions changes should be identified by type of source or activity. 

The analysis must be based on the most recently updated emissions inventory, 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 report that analyzes the change over the past 5 years in 

emissions of pollutants contributing to visibility impairment, disaggregated by source category 

and emissions activity, for significant categories of sources or activities.”

40 CFR 51.308(d)(4)(v) of the RHR requires a statewide 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 pollutants inventoried include VOCs, NOX, PM2.5, PM10, 

ammonia, and SO2. Five emission inventory source classifications were developed and include: 

Stationary point and area sources, off-road and on-road mobile sources, and biogenic sources. 

Throughout the course of its work to develop the Regional Haze SIPs, VISTAS made several 

improvements to the emissions inventory to improve 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 NH3 NOX

PM10-

PRI 

PM25-

PRI SO2 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 43,453 196,821 380,519 108,328 164,444 302,623
Table 14: South Carolina 2007 Emissions Inventory by Source Sector 

State FIPS CO NH3 NOX

PM10-

PRI 

PM25-

PRI SO2 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 NH3 NOX

PM10-

PRI 

PM25-

PRI SO2 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 emissions 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 significant changes in 

anthropogenic emissions within or outside the state 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 indicates that sulfates continue to be the biggest single contributor to regional haze at 

Cape Romain. As indicated, the Department focused its analysis for the SC Regional Haze SIP 

on addressing large SO2 emission from point sources. To this end, as evidenced by the data in 

Figures 3, 4, and 6 above, there have been significant 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 planned shut downs or fuel conversions 

will bring us closer to reaching our RPGs. 

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

While the existing and planned future controls over 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 potential pollutants of concern affecting visibility at Cape 

Romain. 

After ammonium sulfate (64.1 percent), the next largest fraction of regional haze at Cape 

Romain is primary organic matter (POM) (14.4 percent). While sulfates continue to be the 

contributor to visibility impairment, as indicated in Figures 12 and 13, the contributions of POM 

and elemental carbon (EC) are also of concern. 

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

0

10

20

30

40

50

60

70

01/11/200602/07/200604/11/200607/04/200610/14/200612/13/200601/15/200702/05/200703/19/200709/12/200710/03/200712/26/200701/10/200804/09/200807/08/200810/09/200812/17/200801/10/200903/17/200905/16/200909/22/200911/15/200912/12/200901/23/201002/10/201003/18/201006/22/201009/26/201011/13/2010

Sea Salt

CM

Soil

EC

POM

Amm. NO3

Amm. SO4

Rayleigh

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

0

50

100

150

200

250

300

350

400

01/05/200604/02/200605/26/200606/28/200607/31/200609/26/200604/15/200705/30/200707/20/200708/16/200709/06/200711/14/200702/15/200803/28/200806/17/200807/26/200808/19/200809/30/200801/25/200903/14/200906/15/200907/03/200908/08/200909/28/200903/09/201005/02/201007/10/201009/02/201009/20/201012/04/2010

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 Romain monitoring site (45-019-0046) located in 

Charleston County on the five highest POM bext days from 2006 to 2010. This analysis indicated 

that fires reported within and/or outside the state, have contributed 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 sufficient to enable the state, 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 Carolina 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) 46 
As outlined in Table 6 (controls/reductions included in the original SC Regional Haze SIP), the 

actual 2011 CAMD emissions of 66,131 tons of SO2 are already below the 2018 projected 

emissions of 76,291 tons of SO2, with expected further decreases. This information illustrates 

that SC as well as other neighboring states are on track to meet the established RPGs. Moreover, 

these reductions are further elaborated on in the emission reductions information from Table 10 

(installed controls and resulting 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 

SO2 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 requires, “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 Carolina, 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 measurements provide the only long-term record 

available for tracking visibility improvement or degradation and therefore South Carolina intends 

to rely on the continued availability of quality assured data collected through the IMPROVE 

network to comply with the regional haze monitoring requirement in the RHR. 

There 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 

Cape Romain includes: 

 A Tapered Element Oscillating Microbalance (TEOM) for continuously 

measuring PM2.5 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 NO2 and SO2 precursor gasses; and 

 Continuous monitoring of particulate Sulfate. 

Two Optec NGN-2 Nephalometers have been transferred to South Carolina allowing operation 

and backup to minimize downtime required for monitor maintenance or exchange. The operation 

and data reporting was supported in cooperation with VISTAS through 2009 South Carolina has 

continued to support the operation of the Cape Romain nephelometer. SC performs field 

maintenance but uses the IMPROVE contractor (ARS) for instrument support, data management 

and reporting consistent with the bulk of the IMPROVE Nephelometer network. Availability of 

funding to continue contractor support is evaluated annually. 

SC SIPR: Regional Haze Periodic Report (December 2012) 47 
Additional haze-related measurements were made in South Carolina in 2002-2005 as part of 

special monitoring studies by the VISTAS regional planning organization. These studies were 

intended to allow better understanding of source contributions to PM2.5 mass and visibility 

impairment. They included continuous monitoring of sulfate, nitrate, and carbon particulate to 

better understand daily variability in PM2.5 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, the monitoring equipment has been transferred to the Department. 

South Carolina has acquired several continuous sulfate monitors and operates them at urban and 

rural sites to further the understanding of both contributions to PM2.5 mass and the related impact 

on visibility trends in South Carolina. The Department is committed to continued operation of 

non-criteria monitors supporting regional haze investigations where appropriate when support is 

available. 

In addition, the Department operates a PM2.5 network of the filter based Federal Reference 

Method samplers, supported by continuous mass monitors (TEOMs), CSN (chemical speciation 

network) protocol filter based speciated samplers and the continuous particulate component 

(SO4, BC) monitors described above. These PM2.5 measurements help the Department 

characterize particulate concentrations across the state, and therefore aid in the analysis of 

visibility impacts in and near the Class I areas. 

The IMPROVE measurements are central to South Carolina’s regional haze monitoring strategy, 

and it is difficult to visualize how the objectives listed above could be met without the 

monitoring and detailed sample analysis provided 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 reasonable progress toward visibility improvement 

in its Class I areas and plan appropriate activities to ensure future progress. In particular, South 

Carolina’s regional haze strategy relies on emission reductions that will result from the CAIR or 

CSAPR and emissions reductions in neighboring States, which will occur on different time 

scales and will most likely not be spatially uniform. 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 component of the contributions at that site are regional, reductions 

of the IMPROVE network that would impact the existing IMPROVE site or any of the nearest 

regional IMPROVE monitoring sites would eliminates South Carolina’s ability to track the 

progress or effectively plan improvements for the Cape Romain Class 1 area. In the event the 

Cape Romain IMPROVE monitoring is proposed for elimination, South Carolina, in consultation 

with the EPA and relevant federal land managers (FLMs), will seek to develop an alternative 

approach for meeting the tracking obligation, perhaps by seeking contingency funding to carry 

out limited monitoring or by relying 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 will be sufficient to meet the South Carolina or 

RHR data requirements. 

SC SIPR: Regional Haze Periodic Report (December 2012) 48 
Data produced by the IMPROVE monitoring network will 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 data. 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 measurements 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. Therefore, South Carolina is 

encouraging VISTAS and the other RPOs to maintain 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 necessary 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 declaration that further revision of the existing 

implementation plan is not needed at this time; 

(2) If the State determines that the implementation plan is or may be inadequate to ensure 

reasonable progress...the State must provide notification to the Administrator and to the other 

States which participated in the regional planning process...must also collaborate with the other 

States through the regional planning process for 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 implementation 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 plan’s deficiencies within one year.” 

8. Conclusions 

Based on the options above and the evidence presented here, the Department believes it is 

appropriate to submit to the Administrator a negative declaration letter specifying that no 

additional controls are necessary during this, the five-year progress report (see SIP Amendment 

Cover Letter). 

In keeping with the EPA’s recommendations related to consultation, the Department enlisted the 

support of appropriate state, local, and tribal air pollution control 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 aforementioned agencies and sought their 

SC SIPR: Regional Haze Periodic Report (December 2012) 49 
SC SIPR: Regional Haze Periodic Report (December 2012) 50 

input. Comments received as part of this consultation can be found in Appendix D. Those 

comments seen as germane were taken into account in developing this progress report. 

In addition, the Department also published a Notice of General Public 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 interested parties (see Appendix C). Pursuant 

to 40 CFR 51.102 (2011), the Department did not receive a request for a hearing 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 consultation 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, and responses required by 40 CFR 51.308(i)(3).