Appendix D: 

Written Comments and Responses
Consultation Letters 

Below is a list of the consultation letters to date. 

August 1, 2011: Southeastern State Regional Haze Periodic Report Strategy (SEMAP)...3 

60-Day Consultation Communications: 

Example Email: 07/26/2012, Maeve Mason (DHEC), Draft Periodic Update SIP and 

Appendices for FLM/EPA contacts for review and consultation ......................................11 

Letter: 07/26/2012, Robert Brown (DHEC) to Mr. Tim Allen (U.S. Fish & Wildlife 

Service), Draft Periodic Update SIP and Appendices for FLM/EPA review and 

consultation........................................................................................................................12 

Letter: 07/26/2012, Robert Brown (DHEC) to Mr. Bill Jackson (USDA Forest Service), 

Draft Periodic Update SIP and Appendices for FLM/EPA review and consultation........13 

Letter: 07/26/2012, Robert Brown (DHEC) to Ms. Michele Notarianni (US EPA Region 

4), Draft Periodic Update SIP and Appendices for FLM/EPA review and consultation...14 

Letter: 07/26/2012, Robert Brown (DHEC) to Ms. Patricia Brewer (National Park 

Service), Draft Periodic Update SIP and Appendices for FLM/EPA review and 

consultation........................................................................................................................15 

Letter: 07/26/2012, Robert Brown (DHEC) to Mr. Ron Methier (Metro 4/SESARM), 

Draft Periodic Update SIP and Appendices for FLM/EPA review and consultation........16 

60-Day Consultation Communication - Responses: 

Email: 08/07/2012, Patricia Brewer (National Park Service) to Maeve Mason (DHEC), 

Comments on Draft Periodic Update SIP and Appendices ...............................................17 

Email: 09/12/2012, Bill Jackson (USDA Forest Service) to Maeve Mason (DHEC), 

Comments on Draft Periodic Update SIP and Appendices ...............................................23 

Email: 09/17 and 9/25/2012, Michele Notarianni (US EPA Region 4) to Maeve Mason 

(DHEC), Comments on Draft Periodic Update SIP and Appendices................................25 

Letter: 9/20/2012, Kristin Bail (USDA Forest Service) to Robert Brown (DHEC) 

concurrence with Draft Periodic Update............................................................................27 

Letter: 9/25/2012, Meredith Bond for Sandra V. Silva (U.S. Fish & Wildlife Service) to 

Robert Brown (DHEC) concurrence with Draft Periodic Update .....................................28 

Letter: 9/25/2012, Wick Havens (MANE-VU) to Robert Brown (DHEC), regarding 

impacts of South Carolina on Brigantine Wilderness Area, NJ and comments on Draft 

Periodic Update..................................................................................................................29 

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 1
30-Day Pre-hearing SIP Revision Comments: 

Letter: 11/26/2012, Scott Davis (US EPA Region 4) to Robert Brown (DHEC), 

Comments on Pre-hearing Periodic Update SIP and Appendices .....................................31 

30-Day Pre-hearing SIP Revision Responses: 

Response to EPA’s Comment on Pre-hearing Periodic Update SIP and Appendices.......33 

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 2
Regional Haze Periodic Reporting 

Southeastern States Strategy 

August 1, 2011 

I. Introduction and Background. 

This strategy outlines plans to assist with development of periodic regional haze reasonable 

progress reports for the SEMAP states. This strategy includes recommendations for 

assessing current visibility conditions, tracking emission inventory changes, and 

determining the status of emission reductions outlined in the southeastern states’ regional 

haze state implementation plans (SIPs). It also outlines collaboration and consultation that 

will occur between the SEMAP states and various interested parties. 

References are made in this strategy to “VISTAS” and “SEMAP.” These are acronyms for 

two southeastern regional air quality analysis projects: 

 Visibility Improvement – State and Tribal Association of the Southeast (VISTAS). This 

was the original regional haze project conducted by the southeastern states. This project 

operated pursuant to regional haze regulations under the regional planning organization 

(RPO) concept designed by EPA. Air quality analysis work was conducted during the 

VISTAS project to support the submittal of regional haze SIPs for the ten participating 

states. 

 Southeastern Modeling, Analysis, and Planning Project (SEMAP). This multi-purpose 

phase of regional air quality analysis work was initiated in 2009 to support future 

criteria pollutant attainment demonstrations and to meet the next round of requirements 

for regional haze. It is ongoing. 

The VISTAS and SEMAP projects have been managed by Southeastern States Air 

Resource Managers, Inc. in cooperation with the local agency membership of Metro 4, Inc. 

and the surrounding states of Virginia and West Virginia. 

II. Regulatory Requirements. 

Title 40, Chapter I, Subchapter C, Part 51, Subpart P, Section 308 (40 CFR 51.308) 

contains the regional haze program requirements which establish obligations the states 

must meet. 40 CFR 51.308(g) contains the requirements for periodic reports. These reports 

are to describe progress towards the reasonable progress goals outlined in the initial 

regional haze SIPs. This federal regulation may be found in its entirety in Appendix A to 

this strategy. 

40 CFR 51.308 requires that periodic reports must be every five years starting five years 

from submittal of the original haze SIPs. The reports must describe the status of 

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 3
Page 2 of 8 

implementation of all measures included in the regional haze SIP. Emission reductions 

achieved through implementation of the regional haze SIP must be summarized. An 

assessment must be conducted of the most impaired and least impaired days for the 

following: 

 current visibility conditions; 

 the difference between current and baseline visibility conditions; and 

 the change in visibility impairment over the past five years. 

Changes in emissions contributing to visibility impairment must be identified from all 

sources and activities in each state. Emission changes must be identified by source type or 

activity. Emission analyses must be based on the most recent updated emissions inventory 

with estimates projected forward to account for changes during the reporting period. An 

assessment is required of significant emission changes within or outside a state that have 

occurred over the past five years and that have limited or impeded progress in reducing 

emissions and improving visibility. The sufficiency of current SIP elements and strategies 

to meet reasonable progress goals must be assessed. States must review their visibility 

monitoring strategies and identify any necessary modifications. 

At the same time that the progress reports are due, states are to determine the adequacy of 

existing regional haze SIPs. They may provide a negative declaration to the EPA 

administrator if revisions to the regional haze SIP are not needed. If inadequacies are 

identified due to emissions from one or more sources in another state, the state must notify 

the EPA administrator and the other state as well as collaborate with that state to develop 

additional strategies to address the SIP deficiencies. SIP revisions are required within one 

year of identifying an inadequacy in the regional haze SIP due to emissions from sources 

within the state. 

Consultation with federal land managers (FLMs) is required during the process. 

III. Schedule.

Periodic reports describing progress towards the reasonable progress goals for the haze 

program are required of each state every five years with the first report due five years from 

submittal of the initial SIP. The initial SIP submittal will be considered the date that each 

final regional haze SIP was submitted by a state to EPA. 

Regional haze SIPs were submitted by the VISTAS states over the course of nearly three 

years. The North Carolina and South Carolina SIPs were submitted in December 2007. The 

first periodic reports for these states will be due in December 2012. The final SIPs within 

the VISTAS region were submitted by Florida, Georgia, and Virginia in 2010. The periodic 

reports for these states will due in 2015. 

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 4
Page 3 of 8 

The southeastern states will produce a consolidated regional analysis and report template 

with the following EPA expectations in mind: 

 Periodic reports are to be submitted by individual states on or before the due date 

applicable to each state, and 

 Any submittals to EPA that are substantially beyond the development of the 

consolidated report may require updating to reflect current information at the time of 

submittal. 

In order to support the first state deadlines for the periodic reports, all necessary 

collaborative regional work must be completed by June 2012. 

IV. Strategy for Assessment of Current Visibility Conditions. 

Current visibility conditions will be assessed for each Class I area. Available IMPROVE 

measurements for the most impaired and least impaired days at each Class I area will be 

obtained from the VIEWS website. IMPROVE measurements can take up to one year to be 

posted to the VIEWS website. The most recently available data sets will be obtained and 

used for this analysis. For progress reports due in December 2012, 2011 IMPROVE data 

will be used if available. 2010 IMPROVE data will be used if 2011 data is not available. 

These measurements will be used to calculate five-year averages of the annual averages for 

the most impaired and least impaired days. This analysis will be summarized in tables for 

each Class I area. Differences between current and baseline visibility conditions for the 

most impaired and least impaired days will be identified. Also, changes in visibility 

impairment for the most impaired and least impaired days over the past five years will be 

highlighted. Graphs will be presented of annual time series and five-year averages for 

2000-2010. 

Next, this data will be plotted on the original glide slope plots that were created in the 

VISTAS project. In addition, the modeled 2009 and 2018 visibility conditions for the most 

impaired and least impaired days at each Class I areas will be added to these plots. The 

most recent IMPROVE measurements for the most impaired and least impaired days at 

each Class I area will be compared against the glide slope values for the previous five years 

and the modeled 2009 visibility conditions. Cases where the latest IMPROVE 

measurements are above the original glide slope or the modeled 2009 visibility conditions 

will be noted. In these cases, a supporting analysis will examine the components of 

regional haze to try to relate reductions in individual components; e.g., sulfate, with 

precursor emission reductions; e.g., SO2.

Finally, each state will review its visibility monitoring strategy and recommend any 

modifications to the strategy that are necessary. Each state will provide an update regarding 

any monitoring sites that have been added, removed, or modified.

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 5
Page 4 of 8 

V. Strategy for Assessment of Emission Inventory Changes. 

An emissions tracking report will be generated that analyzes the changes in emissions over 

the past five years for all pollutants, disaggregated by source category and state. This report 

will be based primarily on the most recently updated emissions inventory. Although the 

2008 air emissions reporting requirements (AERR) inventory will soon be available, the 

2007 SEMAP inventory should be of higher quality and will be used instead of the 2008 

AERR inventory. The 2007 SEMAP inventory will be compared to the VISTAS 2002, 

VISTAS 2009 (projected), and VISTAS 2018 (projected) inventories. Since the 2007 

inventory is based on information available five years before the earliest periodic reports 

are due (and even longer for any states that choose to submit their reports later), the latest 

available; e.g., 2010, annual AERR inventory data and continuous emissions monitoring 

data for the electric generating unit (EGU) sector will be examined. This will ensure that 

the periodic reports reflect the most current available information on progress made in the 

EGU sector to install additional controls required by various federal and state programs. 

Emissions in each state will be categorized by pollutant (NH3, NOx, PM2.5, PM10, SO2, and 

VOCs) and source category (area sources, fire sources, on-road and non-road mobile 

sources, and EGU and non-EGU point sources). If any pollutant or source category 

combination in the 2007 SEMAP inventory is significantly higher compared to the 2009 

VISTAS inventory and if the pollutant and source category combination; e.g., SO2 from 

EGU point sources, is deemed to be significantly contributing to visibility impairment 

within the state, additional analysis will be performed. Additional analysis will involve 

looking at source classification code level changes in emissions activity. 

VI. Strategy for Assessment of the Status of Emission Controls. 

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 will 

be summarized. This summary will include: 

 A table listing federal programs; e.g., status of the Tier 2 federal motor vehicle 

program, various Maximum Achievable Control Technology (MACT) regulations, and 

non-road engine standards that were included in the reasonable progress goals and, 

where possible, a comparison of the emission reductions used in 2018 modeling against 

actual emission reductions achieved. 

 A table listing all EGU units in the state (and neighboring state(s) as appropriate) that 

had controls assigned to the units in 2018, the current status of those control 

assignments, and the resulting emission reductions. 

 A table listing all Best Available Retrofit Technology (BART” units in the state (and 

neighboring state(s) as appropriate) that had controls assigned to the units in 2018, the 

required compliance date, the current status of those control assignments, and the 

resulting emission reductions. 

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 6
Page 5 of 8 

 A table listing all Reasonable Progress units in the state (and neighboring state(s) as 

appropriate) that had controls assigned to the units in 2018, the required compliance 

date, the current status of those control assignments, and the resulting emission 

reductions. 

 A table listing any other units in the state (and neighboring state(s) as appropriate) that 

had controls assigned to the units in 2018, the required compliance date, the current 

status of those control assignments, and the resulting emission reductions. 

 A table listing additional emission reductions (emission control equipment, plant 

closures, decreased activity, etc) in the state (and neighboring state(s) as appropriate) 

that were not considered or accounted for in the 2018 inventory. 

In cases where controls have already been added and appropriate information is available, 

specific unit emission reductions will be quantified and compared to the 2018 emission 

projections for that unit. In cases where controls have not been added yet, the proposed 

controls will be applied to unit emissions from the 2007 SEMAP inventory or 2010 annual 

AERR inventory and compared to the 2018 emission projections for that unit. This 

comparison will be performed for SO2 and direct PM2.5 from EGU and non-EGU point 

sources contained in the tables developed consistent with the bullets above. In cases where 

significant discrepancies exist, additional analyses will be performed. 

VII. Strategy for Assessment of Current SIPs. 

An assessment will be performed to determine whether the current SIP 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 assessment 

will evaluate current visibility conditions, emission inventory changes, and the status of 

emission controls and reductions. If a state determines the current SIP is sufficient, it will 

provide to the EPA a negative declaration that further revision of the existing SIP is not 

needed at this time. 

If a state determines that a SIP is or may be inadequate to ensure reasonable progress, the 

state will provide notification to the respective EPA region and to the other states and 

FLMs that participated in the regional planning process. These states will collaborate 

through the regional planning process for the purpose of developing additional strategies to 

address the SIP deficiencies. Where a state determines that the SIP is or may be inadequate 

to ensure reasonable progress due to emissions from sources within the state, the state will 

revise its SIP to address the plan’s deficiencies in accordance with its SIP process to meet 

federal requirements. If the SIP is inadequate due to emissions from sources in another 

country, the state will provide notification, along with available information, to EPA. 

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 7
Page 6 of 8 

VIII. Strategy for Collaboration. 

This strategy will be shared with various interested stakeholders. Discussions with 

surrounding states and RPOs, EPA regions, and FLMs will occur in an effort to promote 

the most effective and efficient process. Amendments to this strategy may be necessary as 

this process is initiated and completed. 

The SEMAP states are committed to conformance with the SIP process requirements 

mandated by 40 CFR 51.308 for the periodic review of progress within the regional haze 

program. This includes collaboration with the following: 

 EPA Regions 3 and 4 prior to initiating the formal SIP process by sharing findings and 

conclusions and during the SIP process by submitting draft, proposed, and final SIP 

information. 

 FLMs, with whom consultation will occur during the five-year review and during the 

formal SIP process at the conclusion of the review. 

 Other regional planning organizations and affected states with whom consultation will 

occur during the regional air quality analysis process to ensure that the impacts on the 

SEMAP states are identified, and impacts that the SEMAP states may be having on 

other states and regions are discussed. 

 Other stakeholders such as industries, trade associations, and environmental groups that 

will receive periodic updates throughout the analysis and SIP processes, provided that 

they have an interest in the information. 

IX. Report Preparation and Submittal.

This strategy will be implemented, as stated earlier, with the goal of delivering to the 

participating states a thorough analysis meeting all general requirements of each individual 

state. Development of a report template containing applicable information and analysis is 

anticipated to be a primary work product of this effort. 

States will be expected to take the general information and personalize it as necessary to 

conform to the requirements and needs of each state. Each state will proceed individually 

through its SIP development process with the goal of filing the completed periodic report 

on or before the five-year anniversary date of submittal of the original regional haze SIP. 

This strategy has been developed in consultation with the participating SEMAP states and EPA. Questions may be 

directed to John Hornback, Metro 4/SESARM executive director; or Ron Methier, SEMAP Project Technical 

Coordinator.

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 8
Page 7 of 8 

Appendix A 

Regional Haze Program Periodic Reporting Regulatory Language 

40 CFR 51.308 

The regulatory language in 40 CFR 51.308 that is pertinent to periodic progress reports is 

reproduced below for ease of reference relative to the southeastern strategy: 

(g) Requirements for periodic reports describing progress towards the reasonable progress goals. Each State 

identified in § 51.300(b)(3) must submit a report to the Administrator every 5 years evaluating progress towards 

the reasonable progress goal 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. The first progress report is due 5 years from submittal of the initial implementation plan addressing 

paragraphs (d) and (e) of this section. The progress reports must be in the form of implementation plan revisions 

that comply with the procedural requirements of § 51.102 and § 51.103. Periodic progress reports must contain 

at a minimum the following elements: 

(1) A description of the status of implementation of all measures included in the implementation plan for 

achieving reasonable progress goals for mandatory Class I Federal areas both within and outside the State. 

(2) A summary of the emissions reductions achieved throughout the State through implementation of the 

measures described in paragraph (g)(1) of this section. 

(3) For each mandatory Class I Federal area within the State, the State must assess 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. 

(i) The current visibility conditions for the most impaired and least impaired days; 

(ii) The difference between current visibility conditions for the most impaired and least impaired days and 

baseline visibility conditions; 

(iii) The change in visibility impairment for the most impaired and least impaired days over the past 5 

years; 

(4) 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 recent updated emissions inventory, with 

estimates projected forward as necessary and appropriate, to account for emissions changes during the 

applicable 5-year period. 

(5) 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. 

(6) An assessment of whether the current implementation plan elements and strategies are sufficient to enable 

the State, or other States with mandatory Federal Class I areas affected by emissions from the State, to meet 

all established reasonable progress goals. 

(7) A review of the State’s visibility monitoring strategy and any modifications to the strategy as necessary. 

(h) Determination of the adequacy of existing implementation plan. 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: 

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 9
Page 8 of 8 

(1) If the State determines that the existing implementation plan requires no further substantive revision at this 

time in order to achieve established goals for visibility improvement and emissions reductions, the State 

must 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 

due to emissions from sources in another State(s) which participated in a regional planning process, the 

State must provide notification to the administrator and to the other State(s) which participated in the 

regional planning process with the States. The State must also collaborate with the other State(s) through 

the regional planning process for the purpose of developing additional strategies to address the plan’s 

deficiencies. 

(3) Where the State determines that the implementation plan is or may be inadequate to ensure reasonable 

progress due to emissions from sources in another country, the State shall provide notification, along with 

available information, to the Administrator. 

(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.

(i) What are the requirements for State and Federal Land Manager coordination? 

(1) By November 29, 1999, the State must identify in writing to the Federal Land Managers the title 

of the official to which the Federal Land Manager of any mandatory Class I Federal area can 

submit any recommendations on the implementation of this subpart including, but not limited to: 

(i) Identification of impairment of visibility in any mandatory Class I Federal area(s); and 

(ii) Identification of elements for inclusion in the visibility monitoring strategy required by § 

51.305 and this section. 

(2) The State must provide the Federal Land Manager with an opportunity for consultation, in person 

and at least 60 days prior to holding any public hearing on an implementation plan (or plan 

revision) for regional haze required by this subpart. This consultation must include the opportunity 

for the affected Federal Land Managers to discuss their: 

(i) Assessment of impairment of visibility in any mandatory Class I Federal area; and 

(ii) Recommendations on the development of the reasonable progress goal and on the 

development and implementation of strategies to address visibility impairment. 

(3) In developing any implementation plan (or plan revision), the State must include a description of 

how it addressed any comments provided by the Federal Land Managers. 

(4) The plan (or plan revision) must provide procedures for continuing consultation between the State 

and Federal Land Manager on the implementation of the visibility protection program required by 

this subpart, including development and review of implementation plan revisions and 5-year 

progress reports, and on the implementation of other programs having the potential to contribute to 

impairment of visibility in mandatory Class I Federal areas. 

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 10
Mason, Maeve <masonmr@dhec.sc.gov>

SC Draft Periodic Update for Review

Mason, Maeve <masonmr@dhec.sc.gov> Thu, Jul 26, 2012 at 8:45 AM

To: tim_allen@fws.gov

Cc: "Davis.Scottr@epamail.epa.gov" <davis.scottr@epamail.epa.gov>, "Brown, Robbie" <brownrj@dhec.sc.gov>,

"Reece, Myra C." <reecemc@dhec.sc.gov>

Good Morning,

As you know the Regional Haze Rule requirements at 40 CFR 51.308(g) require periodic reports evaluating

progress towards the reasonable progress goals established in the State Implementation Plan (SIP). Absent

any federal guidance on these submissions, but in order to meet the required deadline, South Carolina has

prepared its draft periodic update for the Cape Romain Wilderness area. This draft SIP is attached for review.

A hard copy will be mailed today via USPS. DHEC requests that you acknowledge this submission as the

formal commencement of the required 60-day review/consultation. As such, we would appreciate your

comments on or before September 25, 2012. Should you have any further questions concerning South

Carolina’s regional haze SIP development, please feel free to contact me.

Thank you.

--

Maeve S.R. Mason, Manager

Regulation & SIP Management

Bureau of Air Quality, SCDHEC

2600 Bull Street

Columbia, SC. 29201

803.898.2230

5 attachments

PS Haze Update 20120727.pdf

79K

SC Regional Haze Mid Course Review Draft_20120727.pdf

1312K

SC Regional Haze Periodic Update Draft_App A_20120727.pdf

1771K

SC Regional Haze Periodic Update Draft_App B_20120727.pdf

287K

20120727 Ltr to Tim Allen RHR Periodic Update Consultation with FLM Agencies.pdf

544K

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 11
SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 12
SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 13
SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 14
SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 15
SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 16
Mason, Maeve <masonmr@dhec.sc.gov>

SC Draft Haze Periodic Update for Review

Patricia_F_Brewer@nps.gov <Patricia_F_Brewer@nps.gov> Tue, Aug 7, 2012 at 3:59 PM

To: "Mason, Maeve" <masonmr@dhec.sc.gov>

Cc: "Brown, Robbie" <brownrj@dhec.sc.gov>, "Reece, Myra C." <reecemc@dhec.sc.gov>, hornback@metro4-

sesarm.org

Mauve,

Well done. I did a quick read through and wanted to tell you I think your

draft progress report is excellent! I am proud to see SC first in

submitting draft report.

I would recommend moving Table 5 and the discussion of all SC EGU and all

planned SO2 controls before Table 1 and 2. Because as soon as I saw Table

1 and 2, I wanted to ask you to add control technology and the data I found

in Table 5. It would be easier just to discuss SC EGU first and then SC

sources that impact NC and GA Class I areas. And since EGU SO2 controls

are the majority of controls included in the long term strategy, those are

the controls that you want to be able to detail.

I was glad to see that you looked at individual days (Figure 11) as well as

average of all 20% worst days over 5 years. The individual days tell you

more about how important individual pollutants are. Also the figure

inserted below is helpful. It is from the IMPROVE 2011 report, Appendix G,

on IMPROVE website

http://vista.cira.colostate.edu/IMPROVE/Publications/Reports/2011/2011.htm.

I will send you pdf with my comments in margins, but all the comments are

how to improve. You are on track, well done.

(Embedded image moved to file: pic11106.jpg)

take care, Pat

Pat Brewer

National Park Service

Air Resource Division

303-969-2153

"Mason, Maeve"

<masonmr@dhec.sc.

gov> To

patricia_f_brewer@nps.gov

07/26/2012 07:37 cc

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 17
AM "Reece, Myra C."

<reecemc@dhec.sc.gov>, "Brown,

Robbie" <brownrj@dhec.sc.gov>

Subject

SC Draft Haze Periodic Update for

Review

[Quoted text hidden]

803.898.2230[attachment "20120727 Ltr to Pat Brewer RHR Periodic Update

Consultation with FLM Agencies.pdf" deleted by Patricia F

Brewer/DENVER/NPS] [attachment "PS Haze Update 20120727.pdf" deleted by

Patricia F Brewer/DENVER/NPS] [attachment "SC Regional Haze Mid Course

Review Draft_20120727.pdf" deleted by Patricia F Brewer/DENVER/NPS]

[attachment "SC Regional Haze Periodic Update Draft_App A_20120727.pdf"

deleted by Patricia F Brewer/DENVER/NPS] [attachment "SC Regional Haze

Periodic Update Draft_App B_20120727.pdf" deleted by Patricia F

Brewer/DENVER/NPS]

pic11106.jpg

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SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 18
Mason, Maeve <masonmr@dhec.sc.gov>

SC Draft Haze Periodic Update for Review

Jackson, Bill -FS <bjackson02@fs.fed.us> Wed, Sep 12, 2012 at 2:54 PM

To: "Mason, Maeve" <masonmr@dhec.sc.gov>

Cc: "Flynn, Thomas" <flynntj@dhec.sc.gov>, "Brown, Robbie" <brownrj@dhec.sc.gov>

Hi Maeve,

Sorry, I did not get these to you earlier today. Here are my comments and we can talk tomorrow if you

would like them submitted as official comments. I am providing them at this time as a fellow cooperator.

I am meeting with the FLM next Monday to discuss my review. I think the official Forest Service

comments from the FLM for Joyce Kilmer, Linville Gorge, and Shining Rock should be if we agree that the

emissions reductions in SC are sufficient to protect reasonable progress at the Forest Service Class I areas

in North Carolina.

Looking forward to talk to you tomorrow, and please call me at 828-257-4815.

Best regards,

Bill Jackson

Air Resource Specialist

USDA Forest Service

Asheville, NC

828-257-4815

From: Mason, Maeve [mailto:masonmr@dhec.sc.gov]

Sent: Monday, September 10, 2012 8:38 AM

To: Jackson, Bill -FS

Cc: Flynn, Thomas; Brown, Robbie

Subject: Re: SC Draft Haze Periodic Update for Review

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 19
Bill,

Sorry to bother you, but thought I would touch base again since we've asked for comments by Sept 25. If you

have some time to chat prior to then about your previous email, we would appreciate it. If not, we'll look forward

to receiving your more formal comments in a few weeks. Thanks again!

--

Maeve S.R. Mason, Manager

Regulation & SIP Management

Bureau of Air Quality, SCDHEC

2600 Bull Street

Columbia, SC. 29201

803.898.2230

[Quoted text hidden]

Jackson_comments_SC RH Mid Course Review_091212.docx

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SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 20
Draft comments – Bill Jackson

1

Page 6 “... as in each mandatory Class I Federal area located outside South Carolina that may be affected

by emissions from South Carolina sources.”  It appears that Cohutta Wilderness has not been included in

the SC analysis, but I think it is within 200 km.

Page 8 ‐ Table 1, does the documents state later which facilities in bold in Table 1 have already or have

plans to implement controls to meet the CAIR or CSAPR rules? [This may be shown in Table 10 and 11]

Page 15 – I am suggesting a sentence be included in the CSAPR section on the number of tons of SO2

and NOx were anticipated with CAIR.

Page 17 – I think it will be helpful to the readers to also describe how TVA’s current plans compare to

the emission estimates for 2018 by VISTAS.

Page 18 – Table 5 is a little hard to follow.  I am thinking that the table should include a column stating

what VISTAS estimated the emissions to be in 2018.  I do recommend keeping the “Estimated Ton

Reduced column (but include the year the reductions are anticipated) and the “Actual Emissions (2011

CAMD).

Page 20 – I was thinking a 200 km radius was used to identify BART eligible sources during the

development of the SC RH SIP.  If so, then Figure 2 should show the 200 km radius.

Page 26 Figure 3 – suggest the two SO2 results with two different red colors, NOx as two different blues,

heat input as a green line.

Page 26 – Do you think the economic down turn contributed to the emissions reductions?  I would

suggest a brief discussion on how the economy may have affected emissions after2008.  Otherwise,

some people may want to argue that it was the economic crisis that caused the improvements in

visibility.

Page 28 – Please include a brief description as a footnote of what each of the bars represent.

Page 31 – I am thinking the Duke Energy – W. S. Lee switch to natural gas will also benefit Cohutta

Wilderness in Georgia.

Page 35 – I am recommending another table be added that shows the VISTAS estimates for 2002 in the

same format as 2009 and 2019.

Page 38 – I think it would be worthwhile to repeat any finding in the SC RH SIP regarding prescribed and

wildfire emissions to visibility at Cape Romain, especially when VISTAS did a modeling analysis (probably

2018) that included increasing emissions from prescribed fires.  I do agree that increase in POC and EC

maybe attributed to burning wildland fires and the concern is worth noting, but also that land clearing

and agricultural burning may also be a factor.  At this time, I do not think the HYSPLIT analysis supports

the findings, but maybe the satellite images and blog information do a better job.   

Appendix A

Page 2 – It appears that your data does not have a normal distribution (i.e. it is skewed) and you should

focus on discussing the median values.

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 21
Draft comments – Bill Jackson

2

Page 4 – “Spikes seen in the POM time graph suggest impacts from fires and will be discussed in the next

section.”  I would suggest “Spikes seen in the POM and EC time graph...”, but it does not look like you

have spikes at the same time.

Page 7 – I do use the PC‐HYSPLIT model.  I am not sure that I agree with how the analysis was

conducted.  The smoke released at 10 meters maybe below the tree tops and I would not anticipate the

majority of these emissions traveling more than a couple of miles downwind because most of the

particles will be deposited out.   

I am not completely clear (hard to read first value on the bottom graphic) on the time step for each

point on the HYSPLIT graphics (is it six hours?).  The graphics show where particles may have originated

that arrived at the monitor at 2000 UTC.  However, I think your need multiple runs to show where the

particles are estimated to have come from for each hour (24 total) at the IMPROVE site on the day of

interest.  My suggestion is the HYSPLIT graphics should be removed.

I do think you can make a case with the Smog Blog entries that there was smoke in the region on the

days smoke was detected by satellites.  Looking at the HYSPLIT results for November 19, 2010 there is

no mention in the blog of high level smoke originating in Ohio, West Virginia and Virginia that could be

impacting the monitoring site and yet some readers may think smoke is coming from these areas.

On April 2, 2010 the particles impacting the IMPROVE site are from the coast of Georgia, but the other

data does not show fires occurring at that location.  However, one of the images seems to indicate there

was smoke originating in South Carolina.

I think an important piece of information is missing and hopefully can be obtained from the South  

Carolina Forestry Commission.  Perhaps the information can presented to as to how many acres of

prescribed fire or wildfire were occurring at various distances from the monitor.  Were there any fires on

the Cape Romain NWR or Francis Marion NF on any of these five days?  Were there any major wildfires

in the region (like south GA and north FL) on any of the five days of interest?

Appendix B

Page 3 Table 1 – Please explain how the (rolling) average is calculated in the text.  Also, please note the

column heading as a rolling (how many years?) average.

Page 4, Figure 2 – Please tell your reader what is meant by “ARP.”

For figures 4 – 7, I think it would be helpful to have a point (no line drawn) at 2018 of where the VISTAS

estimated the SO2 emissions will be in 2018.

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 22
Mason, Maeve <masonmr@dhec.sc.gov>

SC Draft Haze Periodic Update for Review

Michele Notarianni <Notarianni.Michele@epamail.epa.gov> Mon, Sep 17, 2012 at 5:35 PM

To: "Mason, Maeve" <masonmr@dhec.sc.gov>

Cc: "Brown, Robbie" <brownrj@dhec.sc.gov>, Lynorae Benjamin <Benjamin.Lynorae@epamail.epa.gov>, Richard

Wong <Wong.Richard@epamail.epa.gov>

Hello Maeve,

For our SC/EPA monthly call on September 19, regarding the regional haze topic, below are some preliminary

thoughts regarding the State's draft Regional Haze Periodic Progress Report SIP. We can discuss these further

on our call as well as additional feedback. If you have any questions prior to September 19, please feel free to

give Lynorae Benjamin or myself a call.

1. 40 CFR 51.308(g)(4): We believe that additional information is necessary to fully address the

requirement in 40 CFR 51.308(g)(4) to track emission changes over the past five years. We will

work with you to address this comment.

2. 40 CFR 51.308(g)(5): Starting on page 35, the submittal provides an analysis of whether there are

emissions changes that potentially have impeded visibility progress. To fully address 40 CFR 51.308(g)

(5), please include an explicit statement and an explanation which indicates whether there are significant

changes in anthropogenic emissions of concern that have limited or impeded progress in reducing

pollutant emissions and improving visibility.

3. 40 CFR 51.308(g)(6): The State assesses whether its current regional haze SIP is sufficient to meet

reasonable progress goals (RPGs) affected by South Carolina sources to address 40 CFR 51.308(g)(6).

We believe that additional information is necessary to fully address this requirement. We will work with

you to address this comment.

4. Consent Decrees: The SIP revision includes a generalstatus of controls for certain companies under

consent decrees that affect two or more states (i.e., Santee Cooper, INVISTA, and Lafarge). We

believe that additional information is needed to fully address 40 CFR 51.308(g)(2) to clarify the

contributions from the specific facilities located in South Carolina. We will work with you to address this

comment.

Michele Notarianni

Regional Haze Program

U.S. EPA - Region 4

404-562-9031 (phone)

notarianni.michele@epa.gov (e-mail)

"Mason, Maeve" ---07/26/2012 08:48:54 AM---Good Morning, As you know the Regional Haze Rule

requirements at 40 CFR 51.308(g) require

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 23
From: "Mason, Maeve" <masonmr@dhec.sc.gov>

To: Michele Notarianni/R4/USEPA/US@EPA

Cc: ScottR Davis/R4/USEPA/US@EPA, "Brown, Robbie" <brownrj@dhec.sc.gov>, "Reece, Myra C." <reecemc@dhec.sc.gov>

Date: 07/26/2012 08:48 AM

Subject: SC Draft Haze Periodic Update for Review

[Quoted text hidden]

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Haze Periodic Update Draft_App B_20120727.pdf" deleted by Michele

Notarianni/R4/USEPA/US]

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 24
Mason, Maeve <masonmr@dhec.sc.gov>

SC Draft Haze Periodic Update for Review

Michele Notarianni <Notarianni.Michele@epamail.epa.gov> Tue, Sep 25, 2012 at 2:01 PM

To: "Brown, Robbie" <brownrj@dhec.sc.gov>

Cc: "Mason, Maeve" <masonmr@dhec.sc.gov>, Lynorae Benjamin <Benjamin.Lynorae@epamail.epa.gov>, Richard

Wong <Wong.Richard@epamail.epa.gov>

Hello Maeve,

We appreciate the opportunity to provide you with our preliminary thoughts on South Carolina’s draft State

Implementation Plan (SIP) revision addressing the first periodic progress report under the regional haze

program. As requested during our September 19, 2012, call, we have updated our September 17, 2012, email with possible approaches that the State could consider when addressing the informal comments included

in our prior email and repeated below.

As we noted on our call, the U.S. Court of Appeals for the D.C. Circuit (D.C. Circuit) remanded the Clean

Air Interstate Rule (CAIR), without vacatur, back to EPA on December 23, 2008. In response to the

remand of CAIR, EPA promulgated a new rule to address interstate transport – the “Cross State Air

Pollution Rule” (CSAPR) – on August 8, 2011. On December 30, 2011, CSAPR was stayed by the D.C.

Circuit and CAIR was left in place. EPA is reviewing the court decision and will notify the State of the

implications ofthis decision once the Agency’s review is complete. The following are some of our other

preliminary thoughts on your draft SIP revision.

1. 40 CFR 51.308(g)(4): Additional information is necessary to fully address the requirement in 40 CFR

51.308(g)(4) to track emission changes over the past five years. At a minimum, emissions from another

“lookback” year are needed to compare against the updated emissions inventory year of 2007 for all

emissions source categories included therein (e.g., stationary point and area, nonroad and onroad mobile

sources). The State could use existing emissions inventory data for the year 2002 from its 2007 regional haze

SIP to serve as a “lookback” year to cover a five-year period from 2002-2007. In addition, the State might

consider including existing data more recent than 2007 and/or referencing other portions of the SIP narrative

with more recent data. For example, the State could consider including the existing emissions inventory

projection data for the year 2009 from its 2007 regional haze SIP and show how this information compares

to emissions data from earlier time periods. Also, where actual emissions data is available showing changes

that have occurred since 2007 (e.g., EGU SO2 emissions available from EPA), it would be helpful to discuss

how this information illustrates emissions trends closer to the present time period. For example, the SO2

emissions data for EGUs provided in Tables 10 and 11 could be referenced in this discussion. For source

categories where post-2007 numerical emissions data or projections are not readily available, a qualitative

discussion would be helpful.

2. 40 CFR 51.308(g)(5): To fully address 40 CFR 51.308(g)(5), please include an explicit statement and

an explanation indicating whether there are significant changes in the anthropogenic emissions of concern that

have limited or impeded progress in reducing pollutant emissions and improving visibility.

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 25
3. 40 CFR 51.308(g)(6): The State assesses whether its current regional haze SIP is sufficient to meet

reasonable progress goals (RPGs) affected by South Carolina sources to address 40 CFR 51.308(g)(6).

We believe that additional information is necessary to fully address this requirement and support the State’s

determination. To support its determination, the State could consider referencing relevant discussions/analysis

in other parts ofthe SIP Narrative, including graphs illustrating trends in visibility impairment. Alternatively,

the State could summarize overall trends in visibility impairment at Class I areas that South Carolina sources

impact and emissions from these sources, and assess qualitatively whether the emissions and visibility trends

suggest deficiencies affecting achievement of the RPGs. We will continue to work with you to address this

comment.

4. Consent Decrees (pp.13-14): The SIP revision includes a generalstatus of controls for certain

companies under consent decrees that affect two or more states (i.e., Santee Cooper, INVISTA, and

Lafarge). Please include additional information on the status and dates ofthe implementation of controls,

current compliance schedules, and emissions reductions achieved for the emissions units at the South

Carolina facilities subject to the decrees.

Thank you for giving us an advanced opportunity to review the draft SIP revision. We look forward to

reviewing the final prehearing submission during the official 30-day public comment period. Please contact

Lynorae or me if you have questions.

Michele Notarianni

Regional Haze Program

U.S. EPA - Region 4

404-562-9031 (phone)

notarianni.michele@epa.gov (e-mail)

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 26
SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 27
SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 28
SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 29
reduced at the facility.  Pages 8‐9 of the draft SIP include past and projected emissions at the Jeffries

plant but do not identify what pollutant is being addressed.  Page 18 indicates the SIP assumed no

additional controls but that units 1 and 2 would shut down.  Please provide more specifics on the

dates and type of control installed at the Jeffries plant, if any, as well as the pollutants reduced and

levels of reductions.     

 Page 19, Table 5 of the draft SIP includes control date information and status of controls for the

Williams plant.  The “Control Date” field specifies “2002” and the “Status of Controls” field says

“Began Operation in 2010”.  Page 9 of Appendix B of the draft SIP includes Table 7 with SO2 tons

and the associated year.    It appears that emissions sharply decreased in 2010.    Is the 2002

“Control Date” specified on page 19 in error or is that referring to the scrubber listed in the

“Emission Control Included in SIP” field of Table 5?  Was FGD installed in 2010, as suggested by

the BART Determination on page 22?   Please clarify.    

 On page 30 of the SIP, Table 10 shows that the Wateree plant installed a scrubber in 2010,

significantly reducing SO2 emissions.  The Wateree plant is also mentioned on pages 8 and 9 of

Appendix B showing recent significant decreases in SO2 emissions, but it is not clear what

“annual average” means as opposed to “annual actual.”    Clarification of these terms in that

context would be helpful.  Should the Wateree plant be included in Table 5 (pp. 18‐19)?

 A Santee Cooper – Winyah plant is mentioned on pages 18, 22, and 30, with indications that the

plant added scrubbers on four units after 2002, and that SO2 emissions were significantly

reduced at two units.  This information is helpful.

 MANE‐VU suggests revising the discussion of CAIR and CSAPR consistent with the status of

Homer City at the time the progress report is finalized, particularly with regard to the reliance on

CAIR for meeting BART requirements.   

 Please provide a table of emissions by sector by year corresponding to Figure 5 page 28.  This

information will assist MANE‐VU Class I states in assessing changes in emissions from states

outside MANE‐VU that contribute to visibility impairment in MANE‐VU Class I areas.

Thank you for this opportunity to provide comments on your draft Progress Report SIP.

Sincerely,

Wick Havens

Interim Executive Director

Cc: John Hornback, SESARM

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 30
SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 31
SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 32
EPA’s Pre-hearing Comments & Department Responses 

I. Key Comments: 

40 CFR 51.308(g)(6), Page 43: The State assesses whether its current regional haze SIP is 

sufficient to meet reasonable progress goals (RPGs) affected by South Carolina sources 

to address 40 CFR 51.308(g)(6) on page 43 of the SIP Narrative. We believe that citing 

additional information is necessary to fully address this requirement and support the 

State's determination. The State could consider expanding references to existing relevant 

discussions/analysis in other parts of the SIP to support this determination. Alternatively, 

the State could summarize and assess qualitatively whether the emissions and visibility 

trends are sufficient in addressing achievement of the RPGs. We appreciate the 

additional, clarifying email dated November 21, 2012, from Ms. Maeve Mason, South 

Carolina Department of Health and Environmental Control, regarding 40 CFR 

51.308(g)(6) and we understand that the State will be incorporating this information in 

the final submission to address this comment. 

Response: 

In communication with EPA on August 1, 2011, the Department (as part of the 

Southeastern States), communicated that we would not be conducting any additional 

modeling associated with the periodic update, but rather (as required), states would 

perform an assessment of current conditions using the latest 2010 IMPROVE data to 

calculate five-year averages of the annual averages for the most impaired and least 

impaired days. The cumulative assessment would also address and evaluate current 

visibility conditions, emission inventory changes, and the status of emission controls and 

reductions. The Department has addressed these requirements and this comment on page 

43 of the narrative. Furthermore, the information presented in the entire SIP package to 

include Tables 6, 10, and 11 as well as in Appendix B provide a clear rationale for the 

assessment that the Department’s strategies as outlined are sufficient to meet the RPGs 

both for SC and surrounding states. 

II. Other Comments: 

1. Table 12, Page 33: Table 12 provides for the 20 percent best days an updated RPG and 

baseline visibility data. Please clarify if the State is, in this SIP submittal, formally 

adopting this change to the RPGs for the best days. 

Response: 

The Department has clarified the text at page 33 to say that we would like to formally 

adopt the change (albeit slight) to the RPGs for the best days to reflect the most up-todate visibility data. 

2. Section 6.1, Page 33: Under Section 6.1 on page 33, please clarify if the 40 CFR 

51.308 reference is intended to be 40 CFR 51.308(g)(3). 

Response: 

The Department has clarified the text under Section 6.1 to site the reference as 40 CFR 

51.308(g)(3). 

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 33
3. Figures 7 and 8, Pages 35-36: For Figures 7 and 8, it appears that the figure titles may 

be reversed for the best and worst days. Please confirm these figure titles. 

Response: 

The titles to Figures 7 and 8 have been switched such that they now correspond to the 

correct information. 

4. 2009 Base G4 Modeled Inventory, Pages 39-40: On page 39, the submittal indicates 

that a table follows which depicts the “2009 Base G4 modeled inventory,” however there 

is no corresponding table. Please clarify. 

Response: 

The reference to the 2009 Base G4 Modeled Inventory on page 39 of the text has been 

removed. 

SC SIPR: Regional Haze Periodic Update Appendix D December 2012 - 34