# Proposed 

# Revisions

to 

# the



# Alabama State lmplementation Plan

(Regional Haze State Implementation Plan)
Post-Adoption Submittal

### TABLE OF CONTENTS

Part A 

### - Resolution Signed by the Director ofthe Alabama Department of Environmental Management

Part 

### B 

### - Legal Notice Proof ofPublication of Legal Notice Proof ofNotification of Cancellation ofPublic Hearing

Part C - Executive Summary

Part 

### D - Reconciliation Statements

PartE 

### - Legal Authority

Part 

### F - Final Regional Haze State Implementation PlanPart A 

### - Resolution Signedby the Director ofthe Alabama Department 

### ofEnvironmental Management

### ALABAMA DEPARTMENT OFENVIRONMENTAL MANAGEMENT RESOLUTION

WHEREAS, onMarch 9,2008,the Alabama Department of Environmental
Management gave notice of the opportunity for a public hearing and comment on the
proposed revision to the State of Alabama's State Implementation Plan and said proposal
would adopt measures to address regional haze issues in Alabama.
WHEREAS, a public hearing was tentatively scheduled to be held on April 

### 23, 2008,

before a representative of the Alabama Department ofEnvironmental Management, as designated by the Director ofthe Department, for the purpose of receiving additional data,
views, and arguments on the proposed revisions to the Alabama State Implementation Plan;
however, a public hearing was not held because no request for such hearing was received;

and
WHEREAS, the Alabama Department ofEnvironmental Management has reviewed

the written submissionsintroduced into the record, and has prepared a concise statement of
the response to commentsreceived; and
WHEREAS, minor changes have been made to the proposed revision to the State
Implementation Plan pursuant to comments.

NOW THEREFORE, as Director ofthe Department, I hereby adopt the
proposed revision to the State of Alabama's State Implementation Plan to adopt measures to address regional haze issues in Alabama, and 

### I hereby further statethat this revision shall

become effective immediately on the date indicated below.Part 

### B 

### - Legal Notice Proof 

### ofPublication of Legal Notice Proof of Notification of Cancellation ofPublic HearingALABAMA DEPARTMENT OF EIWIROMMIEMTfiMANAGEMENT 

# 3\ 

# 7

NOTICE OF IWELPC WEARING FOR PROPOSED REVISIONS TO THE ALABAMA STATE I[HBLEMENTATHONPLAN (SIP)

Notice is hereby given that the Alabama Department of Environmental Management of the State of Alabama is providing the opportunity for interested persons to request a public hearing and comment on proposed revisions to the Alabama State Implementation Plan (SIP).

If the Department receives a request for a hearing, the hearing will be held on April 23, 2008, at 10:OO a.m. in the Main Hearing Room at the ADEM - Central Office location at 1400 Coliseum Blvd. in Montgomery.

Those requesting a hearing must call (334)394-4360. The deadline to submit a request for a hearing is 5:00p.m. on April 8, 2008. If no requests for a hearing are received prior to this date, a Notice of Cancellation of the hearing will be posted on April 9, 2008, on the Department's website at adem.alabama.aov/PubWearin~s/PubHearings.htm. Interested persons may also call (334) 394-4360 to determine if the public hearing has been cancelled.

The Alabama Department of Environmental Management proposes to amend the Alabama State Implementation Plan to adopt measures to address regional haze issues in Alabama. The Clean Air Act requires States to develop implementation plans that address regional haze near Class I areas. The plan should address making "reasonable progress" toward establishing measures to prevent future and remedy any ex~sting impairment of visibility in mandatory Federal Class I areas which impairment results from manmade air pollution. The purpose of this SIP revision is to fulfill this federal requirement.
In developing this SIP, ADEM met the requirements in the Clean Air Act involving consultation with the Federal Land Managers (FLMs). This was accomplished through conference calls, consultation meetings and through an advanced copy of the SIP for review and comment. Documentation of the consultation meetings and conference calls can be found in Appendix J of the Reg~onal Haze SIP. The comments received from the FLMs on the Draft SIP are located in Appendix P of the Regional Haze SIP.

The Department is also making available for public comment a letter clarifying a Clean Air Act Section 110 State Implementation Plan (SIP) issue. This issue is unrelated to the regional haze issue.
Copies of the proposed SIP are available at a cost of 30 cents per page at each of the ADEM office locations listed below or on the Internet at adem.alabama.~ov/PubHearin~s/PubHearin~s.htm at no cost.
ADEM, Permits & Services Division Attn: Molly Tatum 1400Coliseum Boulevard (P. 0.Box 301463, Zip code 36130-1463) Montgomery, AL 36110-2059 (334) 394-4360ADEM, Birmmgham Field Office Attn: SheilaVail 110Vulcan Road Birmingham, AL 35209-4702 (205)942-6168
ADEM, Decatur Field Office Attn: JanChilders 27 15Sandlin Road, SW Decatur, AL 35603- 1333 (256)353-17 13
ADEM, Mobile Field Office Attn: Karmen Tolbert 2204 Perimeter Road Mobile, AL 36615- 1131 (251)450-3400

Southeast Alabama Regional Planning &

Development Commission 462 North Oates, 4th Floor Dothan. AL 36303

Alabama - Tombigbee Rivers Planning & Development Commission Courthouse Annex 107 Broad Street Camden, AL 36726

East Alabama Regional Planning &

Development Commission 1130 Quintard Avenue Anniston, AL 36201

If requested, a hearing will be held to receive data, views, and arguments from interested persons regarding the proposed revisions. Attendance at the hearing is not necessary to present such data,views, arguments, or comments asthe same may be submitted in writing, but must be received by the Hearing Officer prior to 5:00 p.m. on April 25, 2008.

Written submissions and other inquires should be directed to: ADEM Hearing Officer, Outreach Branch, Permits and Services Division, Alabama Department of Environmental Management, P.O. Box 301463, Montgomery, AL 36130-1463 (street address: 1400 Coliseum Boulevard, Montgomery, AL 36110-2059)or by e-mail at Hearing.officer@adem.state.al.us.
Any person wishing to participate in the hearing who needs special accommodations should contact the Department'sPermits and Services Division at (334)271-77 14 at least five hearing. working days prior to the

This notice is hereby given this March 9, 2008, by authoritv of ADEM

Director

### AFFIDAVIT OF PUBLICATION

# e
THE BIRMINGHAM NEWS COMPANY



### PUBLISHERS 

### OF 

## THE BIRMINGHAMNEWS

Jaoai<ir,- --oinbigbus Pdvers Planim & Developmeni&rnrnlss!on CourthouseAnnex i 07 BroadS:reet Camden, AL 36726 LETICE 3F PUBLIC I-IEAEliuG FOR PROPOSED REVISIONS TG THE ALABAMA STATE IMPLEMENTATION PLAN (Slfi Notice Is herebyglventhat the Alabama Deonrfmant nf

1:tteiested persons io reWest a public hearin and co~me~it on ropose61revi. %ow:o the .&abama State ImplementationPlan (SIP)

requests lor a heanngare 'acelveo prlor lo thls date a "lolze of Cancallsl~nn nf thrr

I lnteres'edpets& I&

call (334) 394-4380to -+'rmlne If the publ~c

In has beencancelled
I=Afabama Department L ivlronmental Manage

' pmposesto amendths arna State lmalnmanta -
...

-. ,.- 'I. . Van to adopt measures

zddress regional haze 'r- ,es In Alabama. The '- !F. an Alr Act requires Sraesto develop iz+,m plansthat 91'1: ,dlhaze near Ch Iar- ecr Theplznshtuldeddress
P.?i-

. .- 

### ,.ng reasonable prog- v,is a, toward establlshlng ,a-rwres to prevenfMure stic remedy any extbtlng Imi,e.:rnent of vlsiblllty In mandatory Federal Class I areas Whlch lmpalrmentre- ;el:? from manmada air

Ing consultatlon w~th the Federal Land Managers (FLMs Thls was accom- pitshedthrough conference calls, consukatlonmeetings a'id rhrough an advanced cup\ of the SIP for revlew and comment Documentar~orl of the consultation meetings and conference calls canbe found In d~x

J of the ReglonaX,"; SIP The commentswed flom the FLMs on the Drafi SIP are kted inAppendix F of the ReglonalHazeSIP Tne Department Is also - rnakmg avallable for publ~c comment a lettercleMylnga Clean Alr Act Sectlon 110 State lmplementatlon Plan (SIP)1- nibissue13 Uk related to the regionalhaze Issue On this day of 

## ARC^

AD.Two Thousand, and eight, Randy S.Crayne

declares that he is the Billing Manager of "The Birmingham News" published in the City of Birmingham, in

the County ofJefferson, in the State of Alabama, and

that the advertisement, a true copy of which is herewith
attached, appeared in "The Birmingham News"

on the following dates:

State of Alabama County of Jefferson

On 

# 3- 1 ,2008,Randy S Cravne
personally appeared before me, who is personally known

to me to be the signer of the above document, and he
acknowledged that he signed it.

My Commission Expires: January 23,2012

Copiesot the proposedSIP are avallableal a cost of 3O-C-?$Epr pge at each ofSTATE OFALABMA MONTGOMERY COUNTY

/ f I i 

## \, ' 

# ,, !-f Before me, ,4~ !' *- I 

## - a Notary Public 

# -
i I in andfor the Stare and County aforesaid, penonally appeared 

## fflfic, &L
who, first being duly sworn accordingto law, deposes and says that she is the

BOOKKEEPER for The Advertiser Company, publishers ofthe The Morrgomery
Advertiser and TheProttuiNe Progress and that the legal advertisement appeared in the Mo~gomeay Advertiser and that there is now due on snid account the sum
of 

# &

- which is due,just and unpaid; and that no pa* of the said
been paid except as herein specified.

Sworn and subyribed before this 

# , ' -jf -;-p dayof ,3 ',JVi 3, ,'(

$ \ L 4:
,_k ,/ Notary Public, ~ont~drner~ CQ., 

### AE

Notice la hereby glven that me Alobomo Department of Envlranmentd McmoaerP-3nt d

Ina and coriwmnt on revlslonstome sate Imple mentalionPlan (SIP)

me ~epomnent re cdves a request for a heodng, the heorlng will be heldon Apdl23,2[8)8, at lW a.m. Inthe Moln Heattng Room at the ADEM - Central ORlce b cation at 1400 Collseum Blvd. InMontgcmeiv.
mose requesting a hearing must call (334) 3964360. me deadline t 0 wbmn a request fa a hearlog Lr 5:W p.m. on ~orii 8. 2008. n no re Management opoaes to amend mLma State Im lementation Plan to 

### &measures to address reglonal tnxe Issues In Alobomo. The Clean Alr Ad reaulres Ginman plons'mat'a+ dress reg- hcne near Class I areas. me plon should address maklng 'reasonable progress' t 0 ward estatdtshl meo- wres to prevez Mure and remedy an exbnng hnpoiment of &~ityIn mandatory Federal Class I areas which Irrr palrment resub from manmode ak pouutlon. mepwposeafthbSIPre vislon LBtofulfRlWsfedefa1 requlrmt.
in developtng tMs SIP. ADEM met the requlre- rnents In me aeon Alr Ad Involvlry- a,-- ...- me oep~tment is UW making available for puW comment a Wer cior#yingaUeanAkAd section 110slote~ rnentakx Flan (SIP) Is- sue. rms tasue la unreklted to me regi0w.i haze hue. Coplss of me SIP are ava~~a cmt Of 30 cents Per e at each of the 

# m olRce locdlons IMed below or on the In- terne! at adernofobom a.gov/PubHearlngrlPub Hearlngs.htm at no cod ADEM, Permits & Sewlces

Boulevard p. 0. Box 301463. Zlp code g,nn&mery. 361301463) AL

(334) 39- - 2204 PMmeWr Road Wle, AL 366151131 (251) 45D3400

~wma - Tombigbee Rivers Plannlng @ 

### 2%EEt ~~;ihwse Annex 107BroodSh6d Camden. AL 36726 EastAlaborna Reglonal planning L Development Commtsslon 1130QulntordAvenue 

## '

AnnMm.AL 36201 1

If requested, a hearing 

### / wlll be held to receive data vlews and argw menk hom Interested mamm reaardina hehhn. Inferested &s may also cali (334 394-4360 to determine$
publlc hearkg has bee;; cancelled. The Alabama Depart- msi?: o: Ei~v~ronmenra,lngs ond fhrough an ac+ vonced copy of fhe SIP for revlew ond corn rnent DoMlmenfatlonof Me consulEoHon meetings and conference calk can befound InAp pendlx J of Me Regional Haze SIP. Thecments received horn the FLMS on lheDrat7SIPare locat. ed In Appendix P of Me RqbnalHore SIP ADEM. MoblleFM mce AHn: KarmenTolbert views, arguments,- or COITmenk os the same may besubmitted Inwrtt- W, but mwt be re- ceived by he Heorlng OfflcerprlortodODpm on Aprll25.XB0 WdI&n BubnWbns and oMer lnquhes should be dhscted to: ADEM Hearing Oftleer. Outreach Branch, Permitsana SewIces Dlvlslon. Nabom Dement of Envlronmental Mana ernent P.O. Box 3014651, ~ont:

, AL 361?&1463

Mont omery AL 36110-2859) or by '~II

Any pers~l wlshlng to e In the heoraccommodaflons

, should contact the De- i parhnenrs Permits and 1 Services Dlvlslon at (338) 1271-7714 at leost flve

Thls noke Is hereby giv- en fils March9,2M8. Dy OuthOMyOf ADEM.

OnlS 'Trey' Glenn. ill Dlrector Mont.Adv. 3/9/08
779922Account Number 1003427

Per~od Ending 03110108 

### LEGAL AFFIDAVIT

Name: ADEM

Sale Rep Laura Lenoir

Questions Please Call (251) 219-5405
ADEM PO BOX 301463 ATTN KAREN DAVIS MONTGOMERY, AL 36130-1463

e Press - Reg~ster Lock Box 171 2 Mob~le, AL 36633-1712

START END P 0 NUMBER I BILLED TIMES DKTE DATE ADNUMBER DESCRIPTION SAUSIZE UNITS RUN AMOUNT

0?109 03109 101303679-03092008 SiPlkiPBAMA DEPARTMENT OF ENVIRONMENTAL MA 671 Words 671 1 228 14

TOTAL

Vlecia Carlson be~ng sworn says that she IS bookkeeper of Press-Reg~ster wh~ch publishes a dally newspaper In the C~ty and County of Mob~le, State of Alabama and attached notice appeared In the issue of
Press-Reg~ster 3/9/2008



# - " 

## ; ~worh to and subscr~bed before me th~s 10th day of March 2008 

# R !

NOTARY PUBLIC

FOR QUESTIONS CONCERNING THIS AFFIDAVIT. PLEASE CALL MECiA CARLSONAT (251) 219-5418 YOU CAN PLACE A LEGAL NOTICE BY EMAlL OR FAX LEGALSGPRESS-REGISTER COM OR FAX# (251) 219-5037 ALABAMA DEPARTMENTOF ENVIRONMENTAL

MANAGEMENT 

### I
NOTICE OF PUBLIC HEARING

FOR PROPOSEDREVISIONS TO THE ALABAMA STATE IMPLEMENTATION PLAN (SIP)
Notice is hereby gtven that the Alabama De artment of Envi ronmental knagement of the State of Alabama is prowdinc the oomrtunitv for interwte; ersons to &quest a- Kbk

deadltneto submlt a request for a hear~ng Is 5 00 p m on Aprl 8 2008 If no requests for z heartng are received ortor tc



### WE APPRECIATE YOUR BUSINESS PRESS REGISTER LOCK BOX 1712, MOBILE, ALABAMA 

### 36633 

### FOR BILLING ENQCBiRIES 

## - CALL (251) 

### 249-5405OR (25%) 219-542l I. P,";lic hsaring has been caocel
I The Alabama 0epartmeit of En vlronmental Mana ement pro Poses to amend tRe Alabama State Implementation Plan tc adopt measures to address re tonal haze issues in Alabama ?he Clean Air Act require' States to deveio tmplementa lion plans that aBdress regiona haze neaf Class I Breas Thc plan should address rnaklnr reasonable progress" towarc

- &



# , establ~sh~ng measures to pre ,vent future and remedy any ex lslin Impairment of v~stb~hty 11 pan3atory Federal Ciass 1 areas whtch impairment resultc from manrnade air The pur ose of th~s 

### sI8kl%-
IS to fuRi~~ th~s federal require ment'ublic Hearings 

# n Welcome to 

### the 

# n ALABAMA
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

(334) 271-7700 1400 Coliseum Blvd. Montgomery, AL 36110 Post Office Box 301463, Montgomery, AL 361 30-1463 Page 1 of 2

Home I Contacts I Alr Ouality Forecast I Mon~tor~n~ I Certificat~on Publications I 

### FAOI FJight Loq I Search I -anization I Contents l Feedback I Related LinksI MWI i Forms I Records Request / eDMR
~efo\lowin&es are provided inAdobe Acrobat format.

YIYV ' -l.P" 

# -

.,, , .'

Division 3 May 9, 

### 2008 10:OO a.m. ADEM Main Hearing

Room

Alabama State Implementation 

### Plan 

# i

ADEM Main Notice of Cancellation April 

### 23, 2008 Hearing



### - The hearing set for Room

April 

### 23, 2008 has

been cancelled. 

# --

Killen Wastewater Brooks High Treatment Facility March 

### 25, 

### 2008 School Gymnasium
Division 6 Chapters 

### 1-0 & 

### 1 1 March 

### 19, 2008 Public Notice

Because one of the reg~onal newspapers d~d Division 6 Chapter 6 not advertise on January 20, rn addtt~on to the hearmg being held on March 

### 19, 2008 

# 1 I:OO p.m. Public Notice March 6, 2008, a second hear~ng w~ll be held on March 19, 2008 at 1 00 

### i I ADEM Main Hearing

RoomPart 

### C

# -

Executive Summary

### Executive Summary
Regional Haze

The Alabama Department of Environmental Management proposes to amend the Alabama State Implementation Plan to adopt measures to address regional haze issues in Alabama. The Clean Air Act requires States to develop implementation plans that address regional haze near Class 

### I areas. The plan should address making "reasonable progress'' toward establishing measures to prevent future and remedy any existing impairment of visibility in mandatory Federal Class 

### I areas which impairment results from manmade air pollution. The purpose of this SIP revision is to fulfill this federal requirement.

In developing this SIP, ADEM met the requirements in the Clean Air Act involving consultation with the Federal Land Managers (FLMs). This was accomplished through conference calls, consultation meetings and through an advanced copy of the SIP for review and comment. Documentation of the consultation meetings and conference calls can be found in Appendix J 

### of the Regional Haze SIP. The comments received from the FLMs on the Draft SIP are located in 

### Appendix P of the Regional Haze SIP.Part 

### D -
Reconciliation Statements

### State ofAlabama's Regional Haze State Implementation Plan Response to Comments Document July 2008

Commenters: United States Department ofthe Interior's Fish and Wildlife Service received 2 1April 2008 United States Environmental Protection Agency- Region IV received 22 April 2008 Southeast Visibility Industry Coalition (SEVIC)received 25 April 2008



### ADEM's Response to Comments by the Fish and Wildlife Service

Best Available Retrofit Technology (BART) Eligible Issues

1. Sanders Lead and Escambia (Natural Gas Processing Plant, Flomaton) donot appear
on the "BART Eligible Unit List" (Attachment H.3) ofthe Regional Haze SIP,but the FWS received hard copies oftheir exemption modeling. Both were below the 0.5 dv impact cutoff. It appearsthat they should appear onthe BART Eligible Unit list.



### RESPONSE: The two facilitieshave been added to Attachment H.3

2. The Alabama Modeling Summary (Attachment H8) ofthe 

### RH SIP lacks the modeling results for the following facilities that appear onthe BART Eligible Unit list, including: Escambia Operating Co Alabama Power Co., Plants Barry, EC Gaston, Greene Co, Gorgas & Miller Chemical Lime Corp., Alabaster and Montevallo Plants American Cast Iron Pipe Company TVA's Colbert and Widow's Creek Plants Sanders Lead Company, Inc Hunt Refining Company BP Amoco Chemical Company,Decatur Works



### RESPONSE: The requested information is in fact included in Attachment H8. The document is formatted sothat you should actually page acrossthe table. It should be noted that Escambia Operating Company- Flomaton is listed in the Attachment as Vintage Petroleum- Flomaton. The table has been revised to reflect both names.

3. There appears to be a contradictionregarding Oak Grove Resources- JCDH in that the Alabama Modeling Summary (Attachment H8- Table 4-6) shows this facility to have a 0.021 dv impact when Table 7.8.4-1 ofthe 

### RH SIP shows an impact of 0.535 dv. This difference should be explained or rectified.



### RESPONSE: Initial modeling forthis facility showed an impact of 0.535 dv at the Sipsey Wilderness Area. However, after review ofthe sources at the facility it was determined that

### the largest source at the facility did not meet the criteria laid out in the BART rule for eligibility. JCDH and ADEM then requested a rerun ofthe facility using the VISTAS BART modeling contractor. This subsequent modeling yielded an impact of0.021 dv. Unfortunately, Table 7.8.4-1 in the SIP Narrative was not updated. This has been corrected.



### BART Determination Issues

Attachment H8 ofthe 

### RH SIP contains State-developed summaries ofthe two BART determinations of Solutia,Inc. and International Paper- Courtland Mill. In addition, we have reviewed the BART determinations submitted by the companies and our comments are below.
A potential issue relates to the significant 4.4 deciview impact of Solutia, Inc. on Sipsey Wilderness Area. Such significant impact portends a closer look at possible controls that might be considered by Solutia, Inc., in its BART determination.


### International Paper- Courtland Mill

4. It is not clear whether the base-case showing a 1.013 deciview impact at Sipsey assumed that the # 

### 1 Combination Boiler was operating in "swing capacity" as is actually the case or whether full-time use was assumed.



### RESPONSE: IP Courtland modeled theNo. 1 Combination Boiler as if it was operating the entire year.

5. A BART Control strategy involves installation of lowNOxburners (LNB) onthe #2 Combination Boiler. That table onpage 5-8 assumes a 30% control performance level and develops a control cost of $585 per ton and a visibility improvement cost of $3,130,000/deciview. The State should strongly consider adopting this BART strategy. Visibility improvement at Sipsey is estimated at 0.083 deciview. However, Attachment D, which serves as the conclusion section, states that only a 10%NOxcontrol is expected from this strategy, resulting in a 0.01 9 deciview improvement. This discrepancy should be explained or rectified. A LNB installation could be expected to result in a 30% control, rather than lo%, so the former numbers seemto be more realistic.



### RESPONSE: IP Courtland was issued Air Permit 707-0001-X015 for the No. 2 

### Combination Boiler which decreases the NOx emission limit to 338.13 lbh by January 1, 

### 2013. This equates to a 28.9 %

### reduction inNOxemissions from this source. IP Courtland's BART Application states that the LNB would result in a 30% reduction in emissions; however, IP expects a 10% reduction in emissions from its present level from the addition of lowNOx burners due to combustion control techniques and practices currently used in operating the No. 

### 2 Combination Boiler which were put in place following the baseline date. The Department has determined that the addition ofLNB and the 30% reduction to the permitted limit isBART.In order to evaluate control rates, IP modeled the No. 2 CombinationBoiler at varying percentages of control. This modeling was intended to evaluate the magnitudes of improvement associated withthe different control levels. Theresults ofthis modeling are reflected in Table 3-2 in IP's BART determination. The numbers in the table represent the average ofthe 9sth percentile concentrations across all ofthe receptors atthe Sipsey Wilderness for each ofthe three years (2001,2002,2003),and not the high eighth high (HXH) per year or the 22nd highest 9sth percentile over the three years. Once IP recognized that the No. 

### 2 CombinationBoiler would need to be evaluated further for control, they began a unit specific analysis. The proposed control level was then modeled, including the other BART subject units. By modeling with the other units included, the 0.019 deciview improvement is likely dampened, and would in fact be higher ifthe No. 2 Combination Boiler was evaluated alone. Based onthis information, the Department agrees with the proposed controls on the No. 2 CombinationBoiler.



### Solutia, Inc.

6. Comment regarding the visibility improvements from Solutia (summarized): 

### In Solutia's BART engineering analysis dated December 2006, the following statement
was included: "A number ofmodel sensitivity analyses conducted to investigate the impact oflarge SO2and NOx emission reduction (i.e., up to 95% control) indicated relatively little effect on visibility impairment. These results suggestthat the atmospherictransport times and chemical conversionrates of gaseous precursors into visibility-impairing particulate matter are too low for there to be a major Class I
areavisibility improvements." FWS believes the statement of "little effect on visibility impairment" is not acceptable. FWS considers the resulting deciview improvementsparticularly with the installation ofwet scrubbers would be significant at reasonable costs and should be considered by the State.FWS indicated that the "zero" 9sth percentile reductions from NOx controls should be reviewed as well as any significant impacts at other Class 

### I areas other than Sipsey.



### RESPONSE: Model predictions were made for the 24-hour visibility impact for two Class 

### I areas (Sipsey and Cohutta). The results showed fairly large exceedances of the 0.5 deciview threshold, which was specifically true for the Sipsey Wilderness area. Therefore, the maximum improvement impact would be expected at the Sipsey Wilderness. Despite Solutia's indication that the visibility impact of SO2and NOx controls would be relatively limited, the facility was required to proceed through the BART process and to propose controls for BART. From the chosen options ofBART controls, an improvement of 0.32 dv is expected from each of Boilers 

### 5 and 

### 6, and an improvement of 0.24 dv for Boiler 

### 7 from SO2controls. The recommendation regarding the installation of wet scrubbers, specifically for the cokingboilers, is discussed in the later comment responses.


### 7. Comment regarding hour limitations for Boilers #5 and #6 and the addition ofwet scrubbers for control: Solutia, Inc. concluded that Boilers 

### #5 and #6 should be limited to no more than 1800hours of operation in a year, primarily being operated only when other units were not in operation; but did not consider this limit to be alimit as aresult ofBART. The FWS considers this to definitely be a BART limit. Solutia's analysis showed that wet scrubbers onBoilers #5 and #6 would cost about $1,000 per ton of SO2and 

### $8.9million per deciview under full operation. FWS considers that these costs are reasonable under the BART guidelines, and the State should consider BART for these units to be wet scrubbers. An operational limit is acceptable to avoid installation of BART control equipment, but such a limit, by itself, becomes BART and requires that permanent, enforceable limits be placed in Solutia,Inc.'s operating permit.



### RESPONSE: In order to comply with the Boiler MACT, Solutia had planned to operate Boilers #5 and #6 with an hourly restriction. The initial submittal (i.e. Engineering Analysis dated December 15, 2006) accounted for the restricted operation in the emission calculations. In Solutia's submittal dated March 16,2007, Solutia evaluated the use of low sulfur coal for Boilers #5 and #6. The cost and emission reductions achieved from the use of low sulfur coal were calculated based on no operational restriction. The Department determined that the requirement to use low sulfur coal would be sufficient for BART; therefore, the hourly operational restriction was not included in the permitting for these units. In reviewing wet scrubbers as BART controls for Boilers 5 and 6, the incremental cost per deciview was approximately $17-$19 Wdeciview for the addition ofwet scrubbers with the usage of low sulfur coal. The cost for the additional control and limited visibility improvement was considered not to be within reasonable costs. Also, the non-air quality impacts were reviewed with the addition of the wet scrubber adding new waste streams of approximately 7300 tons per year per boiler, contributing to landfills. Taking in to account these considerations, the usage of low sulhrcoal without the addition ofwet scrubbers was considered BART.



### . Comment regarding MACT vs. BART Controls for Boiler #7: Solutia, Inc. accepted ADEM's recommendation of BART for Boiler #7 as Rotating Opposed Fire Air (ROFARotamix) forNOx (and mercury) control and the Mobotec Furnace Sorbent Injection (FSI) system for SO2(and mercury) control. These alternatives were primarily chosen to meet the Boiler Maximum Achievable Control Technology (MACT) requirements for the facility. On strictly BART criteria it might be argued that a combination of Selective Catalyst Reduction (SCR) forNOx control and a wet scrubbing alternative for SO2control might be more cost-effective with greater visibility improvement at Sipsey. The ROFA/FSI systems were likely not finalized (e.g.,by a signed Consent Decree under MACT) prior to EPA's publication ofthe BART guidelines (July 6,2005). Therefore, MACT and BART control alternatives should be considered on equal footing without a supposition that MACT is the first consideration. Solutia, Inc. should examine other technologies that may remove mercury and meet MACT standard in concert with bonafide SOz and NOx controls that may best meet the BART criteria (possibly the SCR/wet scrubbing alternative).



### RESPONSE: Although the ROFA system for the No. 7 Boiler was for compliance with the Boiler MACT, Solutia has indeed installed the system on the boiler. Therefore, cost and emissions were based on the ROFA being existing controls. The reported deciviewimprovement for the varying control options was in the zero 9~~~-~ercentile. Th Department has determined that the proposed FSI system in conjunction with the ROFA system would be acceptable BART controls.

9. Comment regarding Boiler #7 SO2andNOx limits: The FWS agrees with ADEM that for Boiler #7 the SO2limit should be 0.40 lb/MMBtu and the NOx limit should be 0.28 lb/MMBtu. The Solutia, Inc., argument that those limits should be 0.47 lb/MMI3tu and 0.36 IbIMMBtu, respectively, allowing for "comparable technology" to reach those limits rather than being bound to FSI and ROFA, allows too much latitude. The use of comparable technology to reach prescribed enforceable limits is acceptable, but to relax the limits and then allow comparable technology seems too permissive.



### RESPONSE: Solutia requested that the SO2and NOx limits be set based on the current permitted limits rather than from the average operational rate of the unit. The Department determined that this was an acceptable request. Additionally, the Department has determined that allowing a comparable technology would be acceptable provided that the comparable technology would be required to meet the proposed SO2and NOx limitations.
10. Comments regarding the Coking Boilers and Cost of Compliance (summarized): No BART controls were selected for Coke Boilers #1 and #2. The FWS believes that using a wet scrubber for SO2 control would be within an acceptable BART cost range and that the State should consider this option. The FWS also advised that there was a discrepancy between the control efficiencies used for the wet scrubbers. The FWS recommend that the 95% control efficiency be used. The FWS indicated that mere statements that the coking boilers would shutdownby the installation of additional controls were not sufficient in justifying the cost of compliance for no controls for the coking units.



### RESPONSE: 

### In Solutia's submittal dated March 16, 2007, Solutia indicated that additional controls on the coking boilers would result in a net loss. The profitability of the coking business was approximately $270,000. Solutia estimated the annual cost of adding SO2 control technology to the coking units would be 

### $1.9M. The added controls would negate the viability of the units and would therefore require the units to shutdown. The Department accepts Solutia's argument regarding the coking units and the cost of compliance. Therefore, no additional controls were selected for these units. The Department agrees that 95% control efficiency for wet scrubbers should be utilized for any further analysis ofcontrols.

11. Comment regarding proposed language by Solutia: Solutiaproposed that the following language be added as a general permit provision: "Other technology(s), on a site-wide or unit-by-unit basis, may be used to satisfy BARTprovided the reduction of SO2andNOx emissions is commensurate with the unit-by-unit specified BART controls and calculated emission rates found in Attachment A, Table 2". FWS wonders why Solutia cannot evaluate other alternatives now since the 

### full implementation ofBART will be within five years.

### RESPONSE: The Department did not agree with Solutia regarding the addition of the above noted statement. This language was not added to the permit(s).



### ADEM's Response to Comments by 

### EPA Region IV


### Key Comments: The following comments must be addressed in the final SIP to meet the requirements ofthe regional haze regulations andlor SIP completeness and approvability criteria.

1. Best Available Retrofit Technology (BART) Emission Limits: The BART limits and associated compliance schedules are required to be in the SIP per 40 CFR 51.308(e): 

### "TheState must submit an implementation plan containing emission limitations representing BART and schedules for compliance with BART



### ... " Attachment H5 of Appendix 

### H provides permits stamped "draft" with no issuance date. In your final SIP, please include the final BART limits and supporting conditions, including the dates they were adopted by and effective in the State.



### RESPONSE: Theprovisos included in Attachment H5 ofAppendix 

### H have been updated to reflect the effective dates and final limits.

2. St. Marks Class I Area and Sanders Lead Company (SIP Narrative, page 

### 79): The Sanders Lead Facility was exempted from a four factor reasonable progress analysis for the St. Marks Wilderness Class 

### I because (1) BART screening modeling was lessthan 0.5 deciview (dv) and 

### (2) the Florida Department ofEnvironmental Protection did not request an analysis in their consultation process.

a. We recommend that the rationale or procedures Florida uses to exempt sources, particularly SandersLead, from a reasonable progress analysis be discussed in the SIP narrative. This may be in the appendices, but it should also be discussed in the SIP narrative.



### RESPONSE: The rationale and procedures used by Florida to exempt sources has been added to the SIP Narrative in Section 

### 7.7.

b. The Florida reasonable progress methodology to identify sources for a four factor analysis involves assessing emissions units having sulfur dioxides (S02) emissions of at least 250 tons per year, and emissions (Q)to distance ratio of greaterthan or equal to 50 (Q/d>=50), and being within 300 

### krn ofthe Class I area. EPA provided Florida comments on a draft of this procedure. It appears that the reasonable progress area of influence (AoI) process is simpler and different from that used by the other Visibility Improvement- State and Tribal Association ofthe Southeast (VISTAS) states. A subsequent review of the Florida AoI process may require EPA to revisit the Sanders Lead exemption from further reasonable progress analysis.

### RESPONSE: The 

### RH rule and subsequent guidance from EPA provides the states with latitude on how to identify sources for reasonable progress analyses. While the state ofAlabama chose to use the VISTAS A01approach for identifying sources with impacts at the Sipsey Wilderness Area, and as a first cut for those Class I areas outside ofthe state which may be impacted by Alabama sources, we do not feel that
a consistent approach shouldbe mandated. 

### ADEM feels it is the responsibility of the state in which the Class I area resides to establish procedures for evaluating reasonable progress for that Class I area. ADEM feels that Florida's approach works best for their Class I areas, and as such,that Alabama would have been contacted by Florida if emissions sources in Alabama impacted those Class I areas to a significant degree. The state ofAlabama will work with the state of Florida and EPA ifthe established procedures change.

c. We recommend that the State remove the part of the rationale related to Sanders Lead being exempt from BART. A facility exempt under BART is not automatically presumed exempt under reasonable progress. This also appears to be inconsistent with the reasonable progress screening methodology that either Alabama or Florida is using.



### RESPONSE: Section 7.7 ofthe SIP Narrative has been revised to remove this language.

3. Breton Island Class I Area, Akzo Nobel Chemical, Inc.

a. Enclosure I includes the facilities that have a greater than or equalto one percent impact at the Breton Island Class I area as presented in the March 3, 2008 Kentucky Regional Haze Prehearing SIP. It is our understanding that this table and similar tables for other Class I areas were developed through the VISTAS Regional Planning Organization (RPO). We recommend that the Alabama SIP discuss why the Akzo Nobel Chemicals, Inc. (an Alabama facility) is omitted from Table 7.6-5 and a four factor analysis.



### RESPONSE: The initial tables developed by VISTAS, and most certainly included in the Kentucky prehearing draft were the starting point for the analysis of sources contributing to the Sipsey Wilderness Area. One ofthe first steps taken after the list was created was to evaluate each unit's 2018 projected actual SO2emissions and compare that to the allowable SO2emissions for that unit. For Akzo Nobel, the Sulfur Recover Unit was identified initially ashaving a 

### 1.54%impact on the total impact at the Sipsey Wilderness. During permitter review, it was determined that the 2018 projected SO2emissions for this unit exceeded the unit's allowed SO2 emissions. When the allowed emissions were input and the percentage recalculated, the unit's impact fell to 0.71%. As such, in the draft SIP, that source was removed from the table associated with impacts onthe Sipsey Wilderness. As per your request, the source has been added back to Table 7.6-6 with the revised emissions and a notation stating that the source contribution is less than 

### 1%.4. Escambia Operating Company- Big Escambia Creek (SIP Narrative, page 

### 79): On page 

### 79 ofthe SIPNarrative, Alabama states that this facility was exempted from the four factor analysis because it was exempted from BART-subjectivity through a SO2permit emissions limitation. If the source had undergone a BART determinationfor this pollutant and source, we would agree with the reasonable progress exemption. EPA's 

### Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program, pages 4-2 and 

### 4-3 of Section 4, allows States the discretion to have a BART control analysis suffice for a reasonable progress control analysis in the first planning period: 

### "Note that for some sources determined tobe subject toBART, the State will already have completed a BART analysis. Since the BART analysis is based, inpart, onanassessment of many of the same factors that must be addressed in establishing the RPG, it is reasonable to conclude that any control requirements imposed in the BART determination also satisfi the RPG-related requirements for source review in the first RPGplanning period



### ... " The Escambia unit has not completed a BART analysis and thus, the citation above does not apply. The four statutory reasonable progress factors must in some way be addressed tojustify the basis for no further control for reasonable progress for this unit.



### RESPONSE: While a BART determination was not completed for this unit, there is also no guarantee that the determination would have yielded any level of control. This permit limitation will provide a roughly 40% reduction in emissions and will most likely result in either end of the line controls or a reduction in operation. For the Breton Class I area, 

### ADEM once again relied on the VISTAS AoI approach for identifying sources with impacts at the Sipsey Wilderness Area, and as a first cut for those Class I areas outside ofthe state, including the Breton Wildlife Refuge, which may be impacted by Alabama sources,. On several different occasions, Alabama and Louisiana discussed the procedures for evaluating reasonable progress as well
asthe mechanism by which sources outside ofLouisiana would be contacted with a request for a reasonable progress analysis. On all occasions, Louisiana did not request that any Alabama sources undergo a reasonable progress analysis. Again
we feel, and Louisiana concurs, that it is the responsibility ofthe state in which the Class I area resides to establish procedures for evaluating reasonable progress. Because Alabama was not contacted by Louisiana, the analysis ofthis source was not required, but rather included to provide that there will be emissionsreductions from this source. The narrative of the SIP has been revised to include these discussions with Louisiana as well asto provide a general discussion of their procedures.


### Recommended Changes: The following comments should be addressed in the final SIP to clearly provide the State's methodology and rationale for the analyses and conclusions presented.A. SIP Narrative- Main Report:

1. Section2.1 and 2.3: Section 2.3 ofthe SIPNarrative references Appendix B for more information on howthe new IMPROVE equation is used to estimate natural background. However, none ofthe documents in Appendix B discuss where the data (i.e. fine particulate matter (PM2.5) species concentration data) used in the new IMPROVE equation was obtained and how it was used in the equation for the Alabama Class I areas. Please clarify.



### RESPONSE: The PM2,5 data used by ARS were downloaded from VIEWS. The data was updated in September 2007 using revised data for natural background provided by the USFS to correct data containing errorspreviously provided by CIRA. VISTAS used the data approvedby USFS. The USFS files have been added to Appendix B for reference and Section 2.3 ofthe SIP Narrative has been revised.
2. Section 4.1.6, Summary ofBASE G2 Baseline Emissions Inventory, page 2 1: The emissions inventory data provided in Table 4.1 for point and area sources do not agree with the dataprovided in Table 4 in Appendix D.3. Please clarify



### RESPONSE: Table 4.1.6-1 in Section 4.1.6 ofthe narrative reflects 2002 actual emissions for Alabama whereas Table 4 in Appendix D.3reflects 2002 typical emissions. A note has been added to Table 4.1.6- 1 to reflect this. Additionally, a table reflecting 2002 actual emissions by county was addedto Appendix D.3 as a companion to the 2002 typical emissions.
3. Escambia Operating Company- Big Escambia Creek:
a. On page 79, the SIP states that apermit limitation of 5200 tons of SO2
was taken by this company to avoid BART subjectivity. Please clarify in the final SIP when this limit was established as an enforceable permit condition (similar to what was done in Table 7.8.3-1 onpage 83)



### RESPONSE: Table 7.8.3-1 was been updated to include this information. However,the draft SIP incorrectly identified the tons per year limitation. The correct limitation is 7963 tons per year.

b. Onpage 81, Big Escambia Creek is listed as a BART-eligible facility. Page 79 discussed how the source was exempt from BART subjectivity. However, Section 7.8.3, "Sources that took Limits to exempt units from BART eligibility, not BART-subjectivity". To avoid confusion,please include a notation in Section 7.8.3 regarding Big Escambia Creek's BART exemption status.


### RESPONSE: The title of Section 7.8.3has been changed to "Sources that took Limits to Exempt Units fiom BART". Additionally, for Big Escambia Creek, we noted in the narrative that this limit relieved the source from completing aBART determination. Finally, as noted above, Table 7.8.3-1 has been updated to include information onBig Escambia Creek.



### 4. St. Marks Class I Area and Step 

### 4 ofthe Reasonable Progress Assessment: Enclosure 2, from the March 3,2008, Kentucky prehearing SIP, shows a 2.3 percent visibility impact from the ExxonMobile Production Company at the St. Marks Class I area. We recommend that the State discuss the four factor analysis for reasonable progress for this facility in this section. Also, please clarify that ExxonMobile Production Company is the same asEscambia Operating Company- Big Escambia Creek.



### RESPONSE: The ExxonMobile Production Company is indeed the same facility as the Escambia Operating Company- Big Escambia Creek facility. As stated earlier in this document ADEM believes that, while a BART determination was not performed for this source, and rightly so, that the reduction is appreciable and will require either source control or reduced operation. Additionally, in ADEM's initial assessment of the A01analyses, it was recognized that this source is located beyond 200 km from the St. Marks Class I area and also that Florida did not request a four factor analysis from this unit. The permit restriction reduces the 2018 SO2percentage contribution from 2.3% to 1.23%. As previously stated,ADEM used the VISTAS AoI approach for determining which sources significantly impact the Sipsey Wilderness. For Class I areas located outside of Alabama, ADEM defers to the state in which the Class I area(s) is located.



### 5. Section 7.2.1 Federal and State Control Requirements: This section presents the
names ofheadquarter facilities which have several plants subject to consent decrees and whose reductions were modeled in the 2018 inventory. We recommend that the dates for control implementation and compliance be provided for the individual plants. As presented this is not clear for the East Kentucky Power Cooperative, Santee Cooper (specific plants are also not listed), Virginia Electric and Power Company (specific plants are also not listed) and Cargill, Inc.



### RESPONSE: Section 7.2.1 has been updated to include the dates for control 

### and compliance as well asthe associated plant names, where available.



### 6. Section 7.8.3 Sources with Limits to be Exempt from BART a. The State must include all BART exemption emission limits in the SIP. Please include in the final SIP the relevant portions ofthe final permits where these limits are established. To prevent circumvention of the BART requirements, we recommend including apermit term or SIP provision that provides any future changes at the BART-eligible source or in its permit that allow for increases in emissions would subject the source to BART review.

### RESPONSE: As noted earlier in this document, source specific limits are written into the provisos included in Attachment H5 of Appendix 

### H. Any increases in emissions associated with these limits will require the source to undergoNSR review, in which a control evaluation and potentially a visibility analysis would be required.
b. Please clarify that the emissions units presented in Table 7.8.3-1 arethe only BART eligible units at Gulf States Paper, Kerr McGee Chemical and Mobile Energy Services Co.



### RESPONSE: The emissions units presented in Table 7.8.3-1 are the only BART-eligible units at these facilities. The table has been revised with a note advising the reader ofthis.

c. It is unclear how the removal ofallpotential emissions could occur through an emission limitation for the Gulf States Paper 

### #2 Recovery Furnace unless the units were shut down or some extremely efficient control was used. The SIP Narrative should discuss how this level of reductions was possible. Also, permits for this facility are not included in Attachment H5- BART provisos.



### RESPONSE: The Gulf States Paper 

### #2 Recovery Furnace permit was voided and the Title 

### V modification was issued on July 13,2007,without the unit included. Accordingly, this date has been included in Table 7.8.3-1, along with
a notification of a name change to the facility from Gulf States Paper to RockTenn Mill Company, 

### LLC. As such, the permit for this facility is included in Attachment H5 identified as Rock-Tenn not Gulf States Paper. The table will also note the shutdown of the source as the explanation of the reduction in emissions.



### d. It is unclear how to equate the maximum heat input to potential emissions for the Mobile Energy Services Company. Also, the SIP Narrative should also clarify what visibility impairing pollutant is involved. The potential emission limit changes should be provided to show how BART subjectivity
was avoided.



### RESPONSE: The BART rule was written for Electric Generating Units (EGUs) with specific capacities (e.g. 750 MW or larger). It is officially "guidance" for all other units, but has ultimately been extrapolated to all sources meeting the requirements for "eligibility". One of the conditions that must be satisfied for a source to be "BART eligible" isthat it must be one of the 26 named source categories. 

### Inthe final rule, the source category 

### Fossil Fuel Boilers of more than 250

### MMBTU/hr heat input was clarified to include only those individual boilers which met that heat input (70 FR 5

### 1 391 10). Accordingly, the Mobile Energy Services Company restricted its heat input for Boiler 

### #6 to less than 250 MMBTUh. Therefore, there is no revised potentialemissions limit to provide that shows how BART 

### eligibility was avoided, not subjectivity.

7. Section 7.8.4: Figure 7.8.4-1 lists Oak Grove Resources ashaving an impact of 0.535 dv, which is greater than the 0.5dv cutoff used for eligibility. This is repeated in Appendix H, Appendix H-8 and H-9. However, the modeling performed through VISTAS in Appendix H-7 (Table 4-4 on page 

### 4-4) lists the impact as 0.021 dv, which is consistent with the claim that the Oak Grove Resources is exempt. Please clarifyand resolve the differences.



### RESPONSE: Initial modeling for this facility showed an impact of 0.535 dv at the Sipsey Wilderness Area. However, after review ofthe sources at the facility it was determined that the largest source at the facility did not meet the criteria laid out in the BART rule for eligibility. JCDH and ADEM then requested a rerun of the facility using the VISTAS BART modeling contractor. This subsequent modeling yielded 

### an impact of 0.021dv. Unfortunately, this was not updated at several places in the SIP. This has been corrected.
8. General: The State provided AoI data for Class I areas that indicated a one percent or greater impact from Alabama's sources. It appears that the Joyce Kilmer AoI data should also be included and show that the Tennessee Valley Authority's Widows Creek unit has a one percent or greater visibility impact. This data would only be added for completeness.



### RESPONSE: The AoI data has been added to the narrative as Table 7.6-4 in its entirety, including the TVA Widow's Creek boiler.



### B. Appendices and Attachments

1. Attachment H5 BARTprovisos:
a. The Escambia Operating Company -Big Escambia Creek major source operating permit excerpt provided in Attachment H5 does not appear to contain the emissions limits used to exempt out ofBARTsubjectivity. Please verify if all intended information is contained in this excerpt.



### RESPONSE: The final provisos including effective dates and final limits are included in Attachment H5 for Escambia Operating Company's Big Escambia Creek facility. However, as was stated earlier in this document, please note that the draft SIP incorrectly identified the tons per year limitation. The correct limitation is 7963 tons per year. This emission rate has been re-confirmed against the modeling performed by the facility and reviewed by ADEM. This may have been the source of confusion.b. Please clarify why permit information is included for the Rock-Tenn Mill Company, LLC.



### RESPONSE: Between the time that initial BART eligible lists were created in mid 2005 and late 2007, ADEM was notified of a name change from the Gulf States Paper Company to Rock-Tenn Mill Company, LLC. As such, the permit for this facility is included in Attachment H5 and identified as Rock-Tenn not Gulf States Paper, but is the same source.
2. Appendix I: Appendix I addresses the archival and access ofBART modeling products developed through the VISTAS technical efforts. The appendix does not discuss how files created through source-specific BART exemption and determination modeling will be archived, maintained and made accessible to EPA and the public. Please address these items in the final SIP.



### RESPONSE: Language addressing the archive, maintenance and accessibility of BART modeling has been added to the SIP Narrative in Section 7.8.4. It states that ADEM is the agency responsible for providing and maintaining these products. 

### Suggested Clarifications: The following comments are suggested clarifications that would be helpful to more clearly portray the information presented.

A. SIP Narrative- Main Report:

1. Federal Land Managers (FLMs) Consultation Procedures: Please clarify what the State's procedures are for continuing consultation with the FLMs as required by 40 CFR 51.308(i)(4). Section 1.6onpage 7 introduces the requirement, and then provides a copy ofthe VISTAS Memorandum ofAgreement and Bylaws. Onpage 99, it states, "ADEM also commits to ongoing consultation with the FLMs..

### ." It is unclear if the VISTAS agreement or the referenced statement on page 99 is intended to fulfill this requirement.



### RESPONSE: Language has been added to Section 1.6tying in the requirement of 40 CFR 51.308(i)(4).

2. Section 2.1, page 

### 9: For clarity, please provide a citation in Section 2.1 andlor Section 2.3 for the location ofthe 20percent best and worst days used in the technical analyses for the Alabama Class 

### I areas. This information appears to be provided in Section 3 of Appendix G. It would be helpful to add areference to the SIP Narrative to the location ofthis information in Appendix G.



### RESPONSE: In both Section 2.1 and 2.3, language has been added to provide the reference to Appendix G.

### Section 2.4, Figures 2.4-1 and 2.4-2 Page 12: It appears that the labels for these figures are reversed. Figure 2.4-1 presents information for the 20 percent cleanest days, but the caption indicated it is for the 20 percent worst days and visa-versa for Figure 2.4-2.



### RESPONSE: The labels for the figures were indeed reversed. They have been corrected.

4. Section 6.3,Page 38: The second sentence ofthis section indicated that Figure 6.3-1 presents information for the 20 percent best days and Figure 6.3-2 presents information for the 20percent worst days. However, the figures appear to be reversed as Figure 6.3-1 presents information on the 20percent worst days and visa-versa for Figure 6.3-2.



### RESPONSE: The labels for the figures were indeed reversed. They have been corrected.
5. Section 6.3, Figures 6.3-3 and 6.3-4, Page 42: It appears that the labels for these figures are reversed. Figure 6.3-3 presents information onNO3but the caption indicated it is for SO4and visa-versa for Figure 6.3-4.



### RESPONSE: The labels for the figures were indeed reversed. They have been corrected.

6. Section 7.2.4, Figures 7.2.4-2 and 7.2.4-3, pages 55-56: These figures present data for two Community Multiscale for Air Quality (CMAQ) modeling runs labeled "CMAQ 2018 g4a" and "CMAQ 2018g2b". The difference between these two modeling runs should be described for clarity. It is assumed that the "CMAQ 2018g4a" refers to the "Best and Final" run, but this should be clarified.



### RESPONSE: Section 7.2.4 has been revised to include a description ofthe two runs, explaining that the difference involves different versions ofthe emissions inventory, including a statement that the CMAQ 2018g4arun is the VISTAS Best and Final run.



### 7. "Section 51.309(d)(3)(v)",Page 89: Please clarify the cited provision related to smoke management on page 89 of the SIP Narrative to cite the Regional Haze regulations in 40 CFR 

### 51.308, rather than 40 CFR 51.309, which applies to four states out West. The correct citation and language isprovided here: "Section 51.308(d)(3)(iv)(l3)."



### RESPONSE: The SIP Narrative has been revised to include the correct citation; Section 5

### 1.308(d)(3)(iv)(E).8. Emissions Tables, Pages 87and 89: To clarify the information in the tables for Solutia and International Paper-Courtland Mill onpages 87 and 88,it would be helpful to correlate the boiler names with the unit "ID'S" and provide a brief explanation of the numbers presented (e.g., emissions projections in tons per year).



### RESPONSE: The tables containing BART information for Solutia and International Paper- Courtland Mill in Section 7.8.5 ofthe Narrative have been revised to include the unit descriptions for the BART Subject sources and language added to the tables identifying the emissions in tons per year. 9. Reasonable Progress Goals (RPGs): Table 8.0-1 on page 

### 94 of the SIP Narrative provides 

### RPG values that do not match the values provided in Table 10-1 of Appendix H on page H-39. Please correct this discrepancy or note the reasons for the difference.



### RESPONSE: The two tables (8.0- 1 and 10- 1 (Appendix H)) have been reconciled and include the values associated with the VISTAS Best and Final modeling for the Sipsey Wilderness Area.
10. One Percent Reasonable Progress Threshold:

a. On Page 70, the State identified a threshold of "greater than 1%" for further evaluating sources for reasonable progress. In other places in the text, the threshold isreferred to as "at least 1%" (page Appendix H-5). Please clarify whether the threshold includes the one percent or not.


### RESPONSE: All references to the threshold used in evaluating sources for reasonable progress have been revised to say one percent or greater, including text and tables.

b. On page 78 ofthe SIP Narrative, a partial summary ofthe State's rationale for selecting the one percent is provided. A complete rationale isprovided in Appendix H, Section 5.0 (no page numbers). To avoid confusion, please consider a reference to Appendix H for the complete discussion.



### RESPONSE: A reference to Appendix 

### H, Section 5.0has been provided in Section 7.7 ofthe SIP Narrative.

The table in Enclosure 1 indicates that there are two Louisiana facilities (i.e. the last two entries in the table, Chalmette Refinery and Murphy Oil) with a one percent impact at the Breton Class I area. These facilities are not presented in Table 7.6-5 ofthe Alabama SIP. For completeness, the State could consider adding them to Table 7.6-5, the fractional contribution analysis table for the Breton area.

### RESPONSE: The two facilities, Chalmette Refinery and Murphy Oil were removed from the Breton fractional contribution analysis because they were subject to consent orders which limited their emissions such that their individual contribution to the total contribution at Breton was lessthan one percent. However, they were added back to the table with their revised percentages for completeness.

d. Please clarify the header in the Tables in the SIPNarrative and Appendix 

### H, Table 

### 5.2 to identify that the listed facilities fall within the reasonable progress screening threshold that the State is using to determine the significant impact at
a Class I area. This would clarify where different thresholds are being used for areas inside vs. outside the State.



### RESPONSE: All tables in Section 7.6 ofthe SIP Narrative and in Appendix H have been revised to say one percent or greater, including text and tables. All ofthe tables are listed as including those sources with impacts ofone percent or greater to the total contribution. However, there is a difference in how the lists were used, depending on the Class I area. The state ofAlabama chose to use the VISTAS A01 approach and the one percent or greater criteria for identifying sources with impacts at the Sipsey Wilderness Area, and as a first cut for those Class I areas outside ofthe state which may be impacted by Alabama sources. ADEM feels it is the responsibility ofthe state in which the Class I area resides to establish procedures for evaluating reasonable progress for that Class I area.

11.Affected BART Facilities: The SIP Narrative and Appendix 

### H provide different numbers ofBART eligible and BART exempt sources. For example,page 82 of the SIP Narrative states 40 sources were originally identified as BART-eligible versus 38 on page H-8. Similarly, page 

### H-17 cites 36 facilities exempt from BART through modeling versus 35 on page 8 of the SIP Narrative. Please correlate these numbers.



### RESPONSE: The numbers of BART eligible and BART exempt sources have been reconciled in Section 7.8 of the SIP Narrative and in the associated Appendices. The corrected numbers, 

### 40 total BART eligible sources and 37BART exempt, are provided here for your information.



### 12.Facilities with Changed Names: We suggest that a notation be added for those facilities whose names have changed. For example, it appears that the ExxonMobile Production Company in Enclosure 2 is the same as the Escambia Operating Company -Big Escambia Creek facility in the Alabama SIP.



### RESPONSE: In Table 7.8.4-1 in Section 7.8.4 of the SIP Narrative, the original facility names have been added in parentheses to help in identifying those sources which have gone through a facility name change.13.Reasonable Progress references: Please clarify inadvertent uses ofthe term "reasonable further progress" and "RFP" intended to mean "reasonable progress".



### RESPONSE: The term "reasonable fh-therprogress" or "RFP" has been replaced throughout the SIP Narrative in its entirety with the term "reasonable progress" or 

### "RP".

B. Appendices and Attachments:

1. Appendix 

### H- Table 5.2: Sinceone Alabama source (TVA Widows Creek) has a one percent impact at the Joyce Kilmer Class I area, data should be added to Table 5.2for this Class 

### I area or at least mentioned in the text discussion.



### RESPONSE: 

### A notation has been made to both Table 7.6.4 in the SIP Narrative and Table 5.2 in Appendix 

### H to discuss how the TVA Widow's Creek unit was evaluated for reasonable progress.
2. Clean Air Interstate Rule (CAIR) Satisfied Reasonable Progress Assessment: Section 6.3, Step 

### 3 of Appendix 

### H on page 

### H-4 provides a summary of the State's determination ifthe CAIR is sufficient for reasonable progress for subject electric generating unit that is provided in full in SIP Narrative; Section 7.7, Step 

### 3. The Appendix 

### H description does not address the four factors as is done in the SIP Narrative. Please consider correlation ofthe two sections, or refer the reader in Appendix 

### H to the SIPNarrative for complete details to avoid confusion.



### RESPONSE: Appendix 

### H has been revised to refer the reBder to the SIP Narrative for more information on the discussion about CAIR satisfying Reasonable Progress for EGU sources.

ADEM's Response to Commentsby the Southeast Visibility Industry Coalition 

### (SEVIC]

SECTION 1 

### .O
Page 2-3: This discussion of the regulatory requirements for each State is misleading because it speaks in terms of requirements for all States when the Rule specifies certain requirements only for a State in which a Class I area is located. SEVIC believes that Alabama's requirements under the Act and the Rule can be stated more clearly by avoiding a collective discussion in terms of multiple States' responsibilities and instead focusing on the requirements for an individual State. For example, it is incorrect to state that "[tlhe Rule then requires states to establish Reasonable Progress Goals (RPGs), expressed in deciviews (dv), for visibility improvement at each affected Class I area


### . . ." 40 C.F.R.5 51.308(d)(l)makes clear that a State must establish RPGs "[flor each mandatory Class 

### I Federal area located within the State." The Rule therefore requiresAlabama to establishWGsonly forthe SipseyWilderness. SEVIC believes the source ofthis confusion may be attributable to questionable EPA guidance that is couched in terms of setting RPGs for each State rather than for each Class I area.


### RESPONSE: With respect to the Regional Haze Rule, it is also ADEM's interpretation that the State ofAlabama is only responsible for establishingReasonable Progress Goals (RPGs) for the Sipsey Wilderness Area. These goals are provided in the SIPNarrative in Section 8.0. It is likely that that EPA's guidance language was intended to generally express the expectations ofthe States.
2. Page 

### 3, 4th: ADEM statesthat BART requirements constitute "a specific component of each state's first LTS." However,the structure ofthe statutory provision that requires BART and the LTS suggests otherwise. Intuitively, it would seem that all control
measures required to meet the RPGs for a given Class I area would be contained in the LTS. But examination of CAA section 169A(b)(2) shows that each SIP must "contain such emission limits, schedules of compliance and other measures as may be necessary to make reasonable progress


### . . 

### . ,including (A) [Best Available Retrofit Technology]; and 

### (B) a long-term (ten to fifteen years) strategy for making reasonable progress


### . . 

## ." In other words, consistent with the structure of the statute, BART is not included within a State's LTS, but instead is a complement to that LTS. Section 169A(b)(2) indicates that BART and the LTS are each a component ofreasonable progress.



### RESPONSE: The SIPNarrative has been revised to state that the BART requirements constitute "a complementary component to each state's first LTS".
3. Page 3, last ADEM states: "If emissions controls are not ontrack to meet SIP forecasts, then stateswould need to take action to assure emissions controls by 2018 will be consistent with the SIP or to revise the SIP to be consistent with the revised emissions forecast." SEVIC believes ADEM's focus is inappropriately based only on emissions and fails to even mention the importance of changes in visibility at Class I areas. The ultimate goal in each planningperiod for each regional haze SIP is to achievethe visibility improvement projected for each Class I area by the end of that planning period. Consequently, just because actual emission reductions are different than what the SIP forecasts doesnot mean that corrective action by the State is automatically required. SEVIC believes the applicable regulations on this matter are misleading. 

### 40 C.F.R. 

## 5 51.308(h)(l) discusses the situationwhere "the existing implementation plan requires no further substantiverevision at this time to achieve established goals for visibility improvement and emission reductions." Of course, there are no established goals for emissionsreductions per sebut only for visibility improvement. Thus, if the visibility improvement goals are being met atthe interim review, the need for any SIP revision is highly questionable, even if emission reductions contemplated by the SIP are behind schedule at that time. SEVIC understands that emission control measures are enforceable,but reasonable progress goals are not.Nevertheless, the ultimate success is measured in terms ofvisibility improvement. In the absence offailing to meet an established goal for visibility improvement, a State may have significant difficulty in strictly enforcing a control measure in the SIP.

### RESPONSE: ADEM agrees that at both the midpoint review conducted in 2012 and again in 2018, an evaluation of the emissions sincethe baseline date aswell as the visibility improvement to date will be required to demonstrate progress towards the visibility goals. As such, the SIP Narrative has been revised to reflect the evaluation of both components.

4. 

## 5 3.0, 2." ADEM's statement that "[elach state must set goals for each Class I area that provide for reasonable progress



### . . ." is simply not correct. As indicated previously, 40 C.F.R. 

## 8 51.308(d)(1) makes clear that a State must establish RPGs "[flor each mandatory Class 

### I Federal area located within the State." (Emphasis added.) The Rule therefore requires Alabama to establish RPGs only for the Sipsey Wilderness.



### RESPONSE: It is also ADEM's interpretation that the State ofAlabama is only responsible for establishing Reasonable Progress Goals (RPGs) for the SipseyWilderness Area. These goals are provided in the SIP Narrative in Section 8.0.
5. Page 15,last: ADEM states that the "Best and Final" 

### runincorporates all final "BART and RFP controls." SEVIC assumes that the acronym RFP stands for "reasonable further progress" or simply "reasonable progress." Is an "RFP control" one that has been specifically required only after an analysis with the statutory factors indicates that such control can achieve reasonable progress? Do the referenced "BART and RFP controls" consist of all such measures required throughout the VISTAS region? Does Alabama's regional haze SIP specifically identify each such BART and RFP control measure, i.e.,name of the source, the State and the nature ofthe control requirement?



### RESPONSE: The term "reasonable hrtherprogress" or "RFP" has been replaced throughout the SIP Narrative in its entirety with the term "reasonable progress" or "RP". ADEM does interpret a RP control as one that has been specifically required only after an analysis with the statutory factors indicates that such control can achieve reasonable progress, although the State is provided discretion in determining what reasonable progress is. Additionally, although the statement about the BART and RFP/RP controls is correct for the State of Alabama, these measures may not be fully reflected for the other states within the VISTAS region. Lastly, the Alabama Regional Haze SIP does contain information about the BART control measures, specifically in the SIP Narrative in Section 7.8.5 as well as in Attachment H5 which houses the BARTprovisos. In regards to 

### RP, for the 2018progress goal, no sources in Alabama were required to apply controls.

SECTION 7.0
6. Page 46, 2nd: Again, the Rule only requires each State to establish RPGs "[flor each mandatory Class I area located within the State." 40 C.F.R. §51.308(d)(l) (emphasis added). See comment onpages 2-3 of SIP.

### RESPONSE: It is also ADEM's interpretation that the Stateof Alabama is only responsible for establishing Reasonable Progress Goals (RPGs) for the Sipsey Wilderness Area. These goals are provided in the SIP Narrative in Section 8.0.

7. 

## 5 7.1,item b: SEVIC believes the question can be more clearly stated as: "If additional emission reductions were needed to achieve further visibility improvement at the Sipsey Wilderness by 2018,what pollutant reductions from what source categories could provide the largest amount ofadditional visibility improvement?"



### RESPONSE: It is ADEM's contention that the current language in the SIPNarrative largely mirrors the suggested language in its intent. However the language has been revised to include a reference to the Sipsey Wildemess Area.



### 8. 

## 5 7.1, item c: SEVIC believes a more appropriate question would be: From what geographic locations would reductions in 2018emissions produce the most visibility improvement at the Sipsey Wilderness?



### RESPONSE: It is ADEM's contention that the current language in the SIPNarrative largely minors the suggested language in its intent. In both cases, the focus is onthose SO2 sources for the purposes of the 2018 goal that, if controlled, would result in visibility benefits. No revision to the SIP is necessary as aresult of this comment.



### 9. 

### 5 7.1, item e:Add "at the Sipsey Wilderness" to the end of the sentence.



### RESPONSE: The language has been revised to include a reference to the Sipsey Wildemess Area.

10.

## 5 7.1, item 

### f: Emission controls do not "represent" reasonable progress; rather, some emission controls may "achieve" reasonable progress. SEVIC believes that confusion easily arises when the SIP uses terminology differently from how it is employed in the statute. The Act's visibility protection provisions say nothing about emission controls or control measures being "reasonable"; rather, the statutory inquiries for both BART and reasonable progress focus on whether visibility improvement achieved by candidate emission control measures will be "reasonable." SEVIC believes this particular question is subsumed within the inquiry ofquestion h.



### RESPONSE: ADEM agrees and as suchhas changed Section 7.1 ofthe SIP Narrative accordingly.

11.

## 5 7.1, item f: The emission controls per se representing BART are immaterial. The question should focus onthe additional visibility improvement in Alabama's Class I area resulting from those BART controls.



### RESPONSE: In reference to item 

### "g", it is ADEM's contention that the current language in the SIP Narrative largely mirrors the suggested language in its intent. No revision to the SIP is necessary as a result of this comment.12.

## 5 7.1, item h: Again, SEVIC believes a more appropriate phrasing ofthe question would ask: "After accounting forthe visibility improvement achieved in Alabama's Class I
area due to emission reductions required by other CAAprograms andby BART, is additional visibility improvement still needed to achieve at least what the glidepath would achieve over the planning period?"



### RESPONSE: It is ADEM's contention that the current language inthe SIPNarrative largely mirrors the suggested language in its intent. No revision to the SIP is necessary as a result ofthis comment. 13. Page 54: In fact,visibility atthe Sipsey Wilderness "is expected to improve to levels better than the glidepath by 201

### 8 based onreductions from existing and planned emissions controls" alone. SEVIC believes that essential point must be clearly made within this SIP inasmuch as the extent to which visibility improvement achieved by an additional control measure (BART or "RFP") is "reasonable" should be heavily influenced by how much visibility improvement has already been achieved by existing and planned controls.



### RESPONSE: ADEM agrees with the comment and the SIP Narrative has been revised in Section 7.2.4 to reflect that visibility at the Sipsey Wilderness "is expected to improve to levels better than the glidepath by 201

### 8based onreductions from existing and planned emissions controls alone."
14. Page 59, 

### 2nd: SEVIC is glad to see ADEM's acknowledgmentthat "[als the atmosphere becomes closer to natural background conditions in the future, the incremental contribution from international emissions will become more important." Of course, that opinion is based onthe presumption that the magnitude ofvisibility impairment attributable to international emissions does not decrease significantly over time. SEVIC believes that ADEM should also recognize that the baseline's inclusion ofvisibility impairment due to international emissions injects a bias into the glidepathby making it steeper than what it would otherwise be when based solely on domestic emissions. This effect may need to be accounted for when a State is comparing its projected visibility improvement in a Class I area to what is actually measured.



### RESPONSE: The EPA and the Federal Land Managers (FLMs) do not agree with SEVIC's comments on accounting for international emissions. It is sufficient for ADEM to acknowledge that international emissions have an incremental contribution. As illustrated in Figure 7.3-2 in the SIP Narrative, domestic emissions dominated the aerosol loading at the Sipsey Wilderness in 2002. Accounting for international emissions would not change our conclusions for reasonable progress in 201

### 8.

15.

## 8 7.4, Relative Contributions: SEVIC believes the results ofthis analysis are misleading, atbest, and possibly could be significantly inaccurate. For assessing potential control measures to achieve reasonable progress in Sipsey Wilderness, VISTAS has identified the relative contributions to visibility impairmentby differentpollutants from different kinds of sources. However, the problem with that analysis is that those relative contributions of different pollutants were determined on the basis of 2009 emissions. Apparently, VISTAS' relative contribution analysis initially was based
onthe 2018 emission inventory. The ultimate results reported in the SIP, however, are based on the 2009 emission inventory. Consequently, the relative visibility impairments at Sipsey Wilderness due to different pollutants fail to account for the substantial reductions in SO2and NOX emissions after 2009, i.e., during implementation of Phase I1 ofthe CAIR and other planned emission controls. Because the discussiononpage 59 states that such determinations ofrelative visibility impairment in 201

### 8 were initially made, SEVIC requests that those results be presented along with a discussion ofwhy they were rejected in favor ofimpairment values obtained from using a nonrepresentative 2009 emission inventory. SEVICrecognizes that ADEM has briefly addressed this matter in section 3.0 of Appendix H ("the full benefits of controls anticipated by 2018 are not included), but that explanation is confusing. Although ADEM states that the reported results based on 2009 emissions are "qualitatively" similar to previous results based on 2018 emissions, SEVIC does not know what that means. Because ADEM has used 2009-based results as a surrogate for 201 8-based results, it is reasonable to expect those results to be "quantitatively" similar. Moreover, SEVIC understands that the results are not expected to represent "absolute" contributions. Indeed, the results are indicative of "relative" contributions, but the substantial CAIR reductions after 2009 suggest that relative contributions in 2009 would not mirror those of201 8. We also understand from the SIPSof other VISTAS States that the determination of pollutants' relative impairment to visibility was based on modeling results from only a few days. Ifthat is the case, then SEVIC requests ADEM to comment on whether that limited data setfor the contribution analysis was sufficiently large to provide statistically representative values for those relative impairment levels. Clearly, as emissions of SO2andNOX decrease substantially from 2009 to 2018 while other pollutants do not, the relative visibility impairment attributable to other pollutants will increase. Thus, while SEVIC does not disagree that the greatest absolute visibility impairment in 201

### 8 will still be due to EGU emissions of SO2, the relative visibility impairments in 2018 attributable to other pollutants should be greater than what ADEM has reported.

### RESPONSE: From the IMPROVE monitoring data, the speciated contributions to light extinction onthe 20% worst visibility days at Sipsey clearly demonstratethat sulfate isthe dominant pollutant ofconcern.

The objective of the emissions sensitivities was to determine the relative benefits of reducing pollutants from different source sectors. The emissions sensitivities were initially performed for 

### 3 short episodes using a preliminary 201 8 inventory. These emissions sensitivities indicated that the greatest visibility response at Sipsey came from reducing SO2 emissions. Responses to changes inNOx and carbon were small in comparison. These results were not used inthe SIP becausethe inventory data was preliminary. Instead 2009 emissions sensitivities that used month-long summer and winter episodes and a more refined inventory were relied on. The sensitivity results using 2009 and 2018inventories were comparable and indicate that the states would see the greatest visibility benefits from reducing SO2from EGU and non-EGU sources within the same state as the Class I area and neighboring states. SOzemissions from EGUs will be reduced between 2009 and 2018; therefore the absolute magnitude of responseto further SO2reductions from EGU would be smaller in 2018 than in 2009. SO2emissions fromnon-EGU point sources are projected to increase slightly between 2009 and 2018, therefore the non-EGU responses shown for 2009 are likely representative ofresponses in 201

### 8. The conclusion that further SO2reductions from EGU and non-EGU sources will be most important remains valid whether 2009 or 2018inventory data is used. Even after implementation of CAIR, in 201

### 8 sulfate still dominates light extinction. This is illustrated below in the comparison of light extinction

# n P

for the 2000-2004 baseline and for the 201

### 8 design value calculated following EPA guidance.

Contributions to Light Extinction at Sipsey 

## - 20% Worst Visibility Days

2000-2004 Baseline 2018

16.

## 5 7.5,Relative Contributions to Visibility Impairment: Geographic Areas of Influence (AOI) at Class I Areas Affected by Alabama Sources: One objective ofthis analysis was to identify the Area of Influence for Sipsey Wilderness, i.e., the specific geographic area containing the point source SO2emissions that most likely influence visibility at that Class I area. Once such an area was defined, the second objective ofthis analysis was to identify specific SO2emission sources in that area that would be candidates for control measures to achieve reasonable progress 

### in the Sipsey Wilderness. SEVIC believes that some ofthose candidates for reasonable progress controls couldhave been inappropriately identified as such dueto the questionable method for defining Sipsey's
area ofinfluence. ADEM states at page 67that Sipsey's "A01 was defined asthe counties with maximum sulfate extinction weighted residence time greater than 

### 5%." That analysis consisted offirst plotting residence time using five years ofback trajectories for the 20% worst visibility days in 2000-2004. (Page 63). Then, each back trajectory was weighted by sulfate extinction for that day. In other words, Sipsey's area ofinfluence was determined solely onvisibility levels at Sipsey dominated by sulfate during 2000-2004. Once that geographic area was defined, candidate sourcesfor "reasonable progress controls" were then identified. SEVIC believes the analysis to define Sipsey's area ofinfluence is flawed because it was based onthe wrong data, i.e., visibility levels dueto SO2emissions during 2000-2004. Major SO2emission reductions will occur between 2004 and 201

### 8 dueto CAIR and other planned control measures.Thus, the area of influence should have been defined based upon projected SO2 emissions which remain after all existing and planned control measures have been implemented. ADEM indicates that it may have attempted to adjust for the flaw in its analysis by first determining which major categories of SO2emissions had the greatest residual contribution to the area in 201

### 8 and then accounting within eachcategory for the SO2reductions projected to occur between 2002 and 2018. (Page 68). But that adjustment ignores the fact that those sources within the area of influence had already been defined based on impacts from SO2emissions during 2000-2004. In effect, VISTAS'IADEM's "adjustment" was made to the wrong population of SO2sources. SEVIC believes that an appropriate area ofinfluence for Sipsey would have been based on 201

### 8 SO2emissions projected to remain after implementation of all existing and planned SO2controls. The SO2sources contained within that area would then constitute the appropriate population from which candidates for "reasonable progress controls" could be selected.



### RESPONSE: The VISTAS Area of Influence (AoI) analyses were released to the VISTAS workgroups in September and November 2006 for review and stakeholders had several months to comment on the design of these analyses. The monitoring data and emissions sensitivity analyses established that SO2emissions were the most important to control to improve visibility so the AoIs focused on SO2 emissions only. The geographic AoIs defined in the maps are based on 2002 emissions. However the population of sources that were considered for the reasonable progress analyses was based on 2018 emissions and 

### 3 selection criteria:
1) sources within the geographic area of influence defined by RTmax>lO% using 2018 emissions, 2) Q/d 35using 201 8 emissions, and 

### 3) 2018 emissions 

### 2250 tons.

The sources were ranked based on 2018 SO2 emissions. A large source outside the geographic area of influence would still be captured in the evaluation because its emissions would be 

### 2 250 tons or Q/d would be 

# > 5. These methods allowed Alabama to prioritize which of many sources were most important to consider in the reasonable progress analyses. These methods were sufficient for this demonstration.

17. Page 

### 76, 1st: ADEM states that the "Rule" requires the consideration of four factors in selecting reasonable progress goals. SEVIC is aware of the considerable controversy surroundinghow reasonable progress goals should be determined, including EPA's position that visibility improvement is not considered in determining reasonable progress goals. However, SEVIC strongly believes that a reasonable progress analysis that fails to consider visibility improvement is fundamentally, if not fatally, flawed. The plain language of the "Statute" (not the "Rule") states that "[iln determining reasonable progress there shall be taken into consideration the costs of compliance, the time necessary for compliance, and the energy and nonair quality environmental impacts of compliance, and the remaining useful life of any existing source subject to such requirements." 42 U.S.C. fj7491(g)(l). In that context, the statutory term "progress' isnothing more than a synonym for "visibility improvement." Black-letter lawholds that when the provisions of a regulation (the Rule) conflict with the provisions ofits underlying statute (the CAA), the provisions ofthe statute must prevail. Thus, regardless ofADEM's understanding ofwhat the "Rule" may require, ADEM is inescapably bound by the Clean Air Act provision that requires four, listed statutory factors must be considered in determining reasonable visibility improvement. The statute says absolutely nothing about determining a "reasonable control measure." Rather, section 169A of the Act instructs States to consider four specific factors when determining whether visibility improvement achieved by aparticular control measure is reasonable. Moreover, the so-called "four-factor analysis" is a gross misnomer that masks the importance ofvisibility improvement in any reasonable progress analysis. 

### In short, the adoption of terminology such as "four factor analysis" and "reasonable control measure" only serves to distort the actual statutory command for "determining reasonable progress." The flawed structure ofADEM's reasonable progress analyses in its draft SIP isnot material inthis particular instance due to the substantial reasonable progress which will be achieved at Sipseyby 

### 2018 due to other existing and planned CAA programs. Because the total ofthose visibility improvements from other programs is already greater than what could be achieved with Sipsey's uniform rate ofprogress (visibility improvement), the State would be hard-pressed to find any further visibility improvement, in the context ofthe statutory factors, to be "reasonable." That may well not be the case during the next regional haze planning period. For that reason, it is imperative that ADEM's approach to determining reasonable progress be re-structured to conform to the Clean Air Act. Such an analysis that fails to consider the visibility improvement associated with a candidate control measure defies any common-sense notion ofwhat is meant by "reasonable progress."



### RESPONSE: ADEM agrees with the concept that a reasonable progress analysis that does not include an assessment of visibility improvement is contrary to the intent ofthe Regional Haze Rule. ADEM strongly holds that the process used in identifying and evaluating
sources for a four factor analysis will need to be revisited and revised for the next planning period.
18. Pages 76-77: SEVIC believes that any reasonable progress analysis must be performed
on a source-specific basis to have any meaningful and discernible results. For example, when attempting to determine the visibility improvement associated with a group of sources, how could emission controls bejustified for a particular member of that group if such controls on that particular source would result in no visibility benefit? For that reason, SEVIC regards the discussion ofthe statutory factors on pages 76-77 as providing no support to any reasonable progress assessment for aparticular source. For example, the discussion about "cost of compliance" (the statutory factor is clearly "costs of compliance") only contains various generalities about certain technical and administrative matters that can affect the use of coal, oil and FGD systems. The discussion does not, however, reflect ADEM's understanding ofthe various ways in which compliance costs may be expressed and evaluated. EPA's method of assessing that statutory factor consists of little more than mechanically calculating a $/ton value for a particular control measure and comparing it to some ill-defined $/tonvalue thatEPA has concluded is "reasonable." Those costsreflect absolutely nothing about the relevant objective ofthe statute, i.e., visibility protection. Thus, while EPA's "fourfactor" approach typically gives great weight to selecting "reasonable control measures" on the basis of their relative $/ton costs, that "costs-of-compliance" analysis fails to identify any costs associated with reducing visibility impairment in a particular Class I area. Again, ADEM's failure to perform reasonable progress analyses that are faithful to the statutory command for "determining reasonable progress" is of little consequence for this particular SIP due to the major amount ofvisibility improvement resulting from other CAA programs by 2018. A similar approach to determining reasonable progress in any future regional haze SIP, however, will almost certainly be catastrophic since the SIP will lack any adherence to an objective assessment of visibility improvement contemplated by Congress.



### RESPONSE: ADEM strongly holds that the process used in identifying and evaluating sources for a four factor analysis will need to be revisited and revised for the next planning period. However, while Sections 7.6 and 7.7 lay out the process for the identification of these sources, that analysiswas completed to provide information on those sources which have an impact on a specific Class I area, in this instance the Sipsey Wilderness area. The
one source in Alabama (Cargill, Inc. Unit S-407) required to perform a four factor analysis completed a source specific analysis.

19. 

## 5 7.7, Step 1: SEVIC is mindful of the fact that "VISTAS evaluated the species contribution on the 20% worst visibility days" determined on the basis of a 2009 emissions inventory. As such, that evaluation introduces an inherent negative bias in the individual species fractions reported for all pollutants other than SO2andNOx.



### RESPONSE: The monitoring data and the 2009 and 2018 emissions sensitivities and air quality modeling results clearly indicate that SO2reductions would be the most important for improving visibility. As illustrated above in comment 15, in 2018 sulfate still dominates light extinction on the 20% worst visibility days. The analyses performed are consistent with Tables 7.5.5-1 and 7.5.5-2 in the SIP Narrative for the Sipsey Wilderness.

20. 

### $ 7.7, Step 

### 3: A reasonable progress analysisfor an entire subcategory of sourcesis understandable in this case because of the interactions between CAIR and the regional haze rule. In essence, ADEM's reasonable progress analysis for CAIR-subject EGUs found the "costs of compliance" and the "time necessary for compliance" determinative for that analysis. What ADEM fails to acknowledge, however, is that it also found the substantial visibility improvement achieved by CAIR to be determinative. Thus, "the State concludes that CAIR controls satisfy reasonable progress for SO2for the first planning period ending in 2018." Although SEVIC fully concurs with ADEM's ultimate finding for that reasonable progress analysis of CAR-subject EGUs, we believe it would be more accurately stated by the following: "The State concludes that any additional EGU controls beyond those required by CARwould not achieve reasonable progress during the first planning period."

### RESPONSE: It is ADEM's contention that the current language in the SIP Narrative largely mirrors the suggested language in its intent. No revision to the SIP is necessary as a result of this comment. 

## 5 7.7, Step 4: ADEM's explanation for why it identified sources causing 1%or more of Sipsey's visibility impairment as candidate sources for reasonable progress analyses is not compelling. The first example involving a 0.5 dv impact correlating to a 5% change in visible perceptions seems very different from setting a cut-off level in terms of relative visibility impairment. Each ofthe remaining three examples involves setting a cutoff as apercentage of a fixed value, and thus the magnitude ofthat cut-off value is fixed. By comparison, the magnitude ofADEM's 1%cut-off value for visibility impairment will vary as a function ofthe total visibility impairment in each Class I area. Thus, a source's magnitude ofvisibility impairment may be identical for two Class I areas, and yet it would be selected for a reasonable progress analysis for one area (>I% impact) but would not be selected for areasonable progress analysis forthe other area (<I%impact). Intuitively, one would expect a reasonable progress analysis to be required only if a control measure has the potential to reduce visibility impairment at least by a minimum amount. Selection ofreasonable progress candidates based on VISTAS'/ADEMYs

### 1%cutoff approach does not satisfythat expectation. In sum, selecting sources having avisibility impact of 1%or more for reasonable progress analyses appears to be arbitrary and provides no assurance that emission reductions from such a source could improve visibility.



### RESPONSE: ADEM respectfully disagrees that the 1% cutoff approach appears to be arbitrary and provides no assurance that emission reductions from such a source could improve visibility. EPA guidance provided no set criteria for determining a visibility impact threshold. In an attempt to "reasonably" identify sources for further review, and recognizing that the 

### RH Rule allows for statesto use their discretion in making these determinations, ADEM evaluated several other established thresholds in selecting the 1 % threshold. This threshold allowed ADEM to narrow the pool of sources to a manageable number while retaining those that were most likely to impact the Sipsey Wilderness Area.
22. Page 79, Step 

### 5: For the first planning period, ADEM's deminimis cost threshold of $2,000 per ton of SO2is reasonable. No control measure for non-EGUs in Alabama could be installed for less than $2,000 per ton. Thus, SEVIC concurs with ADEM's finding that additional control measures on any non-EGU would not achieve reasonable progress in the first planning period. Such a cursory analysis is acceptable in this instance, as SEVIChas noted earlier, dueto the substantial amount ofreasonable progress that will be achieved at Sipsey by 2018 due to emission reductions required by other CAA programs. However, ADEM will likely need more detailed, objective reasonable progress analyses for its next regional haze SIP, so SEVIC encourages ADEM to design a more comprehensive structure for performing a reasonable progress analysis that incorporates the language and intent of section 169A of the Act. In particular, SEVIC highly recommends an analytical methodology that not only incorporates visibility improvement within that analysis, but also evaluates the costs of compliance relative to the resulting benefit, i.e.,visibility improvement.

### RESPONSE: ADEM stronglyholds that the process used in identifying and evaluating
sources for a four factor analysis will need to be revisited and revised forthe next planning period.

23. Page 80,4", 1 st sent.: Section l69A does not "direct states to assess certain



### ... older emission sources" for BART. (Emphasis added.) When section 169A was enacted in 1977,Congress directed States to evaluatethe applicability ofBART to certain sources that were no older than 15years old. The fact that the States are now evaluating older sources for BART applicability is due to the 30-year delay inresponding to that statutory requirement. In this regard, SEVIC believes that VISTAS'IADEM's pattern of attributingmany ofthe regional haze requirements to EPA's direction inappropriately downplays the importance ofthe actual directionby Congress. Many ofthe regional haze requirements for States flow directly from statutory language within sections 169A and 169Bofthe Act. EPA rules must implement those statutory requirements. The legislative history of those statutory provisions makes clear that Congress intended for the individual States to exercise considerable flexibility and discretion when responding to the statutory requirements. Nevertheless, SEVICbelieves that concept seems to have been replaced throughout much ofthe regional haze planning process by the States responding instead to EPA directionthat at times conflicts with the Act's requirements.



### RESPONSE: Section 7.8 ofthe SIP Narrative has been revised to state that Section 169A directs states to assess certain emissions sources which meet specific criteria for additional controls in order to addressvisibility impacts. The Narrative continuesby providing the BART eligible criteria.

24. Page 82, 1st:VISTAS modeling did not actually demonstrate that "VOCs and NH3 from point sources are not visibility-impairing pollutants." VOCs andNH3 are each a "visibility-impairing pollutant," and no amount of modeling can change that. However, SEVIC understands that VISTAS modeling did showthat VOC emissions did not contribute to visibility impairment at Class I areas within the VISTAS region. Likewise,
we understood that ADEM's modeling determined that ammonia from point sources are not anticipated to contribute significantly to visibility impairment in Class I areas. With respect to that latter analysis, SEVIC notes ADEM's statement that "the majority of NH3 emissions in the VISTAS region are from a few BART sources." (App. H, p. H15.) We assume ADEM bases that statement only on point source emissions in the region because Alabama's 2002 emissions inventory on page 22 indicates that area source emissions ofNH3 in the State are roughly 30 times greater than those from point
sources.


### RESPONSE: Section 7.8.2 ofthe SIP Narrative has been revised to state that ADEM and VISTAS have determined that point source emissions ofVOCs do not contribute to visibility impairment at Class I areas within the VISTAS region.

25. Page 83, 2nd: The first sentencemisrepresents the BART liability of certain sources. For
a stationary source to be subject to BART, the statuterequires, among other things, thatit "emits any air pollutant which may reasonably be anticipated to cause or contribute to any impairment ofvisibility in any [ClassI] area." 42 U.S.C. tj 7491(b)(2)(A). Thus, if it canbe shown that a source does not cause or contributeto visibility impairment in a Class I area, SEVIC asserts that ADEM must, rather than "may," exempt the source from BART. That is, ADEM has no discretion to apply the statutory exemption. SEVIC also points out that this exemption provision comes straight from the Clean Air Act. Therefore, identifying the exemption as originating "[ulnder the BART Guidelines" does not convey the full weight of its underlying statutory authority.



### RESPONSE: The BART Guidelines provided the States with several options for identifying the sources subject to BART. The Guidelinesreaffirmed that a State may choose to consider all BART eligible sources to be subject to BART, and to make BART determinations for all its BART eligible sources. However,the State ofAlabama chose to consider exempting some or all oftheir BART eligible sources from review through an individual source attribution approach which is believed to be consistent with 40 CFR 

### 51.308(e)(l)(ii). The first step in determining whether sources cause or contributeto visibility impairment for purposes ofBART was to establish a threshold against which visibility impact is measured. The Guidelines afforded states with latitude in choosing that threshold, stating 

### "Becausecircumstances will vary indifferent locations, we believe that States should have discretion toset anappropriate threshold depending on the facts of the situation. We believe, however, that it would be df$cultfor 

### a State to justifi a threshold higher than 

### 0.5deciviews. "70 FR 39121. For this reason, the Stateretained the authority to decide whether a source "may" or "may not" be exempt from BART.



### 26. Pages 98-100: SEVIC understands that ADEM's interim review will necessarily need to evaluate both changes in emissions and changes in visibility. But the interim review
serves to support the required report on reasonable progress. Therefore, as noted in our comments onthe last paragraph ofpage 3 ofthis SIP,ADEM must take care not to let emission reductions be viewed as a surrogate forvisibility improvement. Simply put, the success ofthe SIP should be measured in terms ofvisibility improvement.



### RESPONSE: ADEM agrees that the midpoint review conducted in 2012 (and again in 2018) should include an evaluation ofboth the emissions since the baseline date as well as the visibility improvement to date to demonstrate progress towards the visibility goals.

### Part 

### E 

### - Legal AuthorityMarch 

### 13, 1991



### Mr. 

### Greer Tidwell Regional Administrator US, 

### Environmental Protection Agency Region IV 345 

### Courtland Street, NeE6 

### Atlanta, Georgia 30365



### Dear MI, 

### Tidwell:
This letter is to notify you that 

### I have designated the 

### Alabama Department of Environmental Management 

### (the Department) 

### as the lead state agency for the purposes of Alabama's responsibilities under the Federal Clean 

### Air Act. 

### The Departme is 

### authorized to take all actions necessary and appropriate to secure to the state the benefits of 

### said 

### federal act under the Alabama ~nvironrnental Management Act, Code of Alabama 1975, 

### Section Zi-iZA-4(n), and by implicatio;; through the Alabama 

### Air iPollution control Act, 

### Code of 

### Alabama 1975, 

### Section 22-28-11(1



### And! (141,


### This action that 

### I ag 

### taking 

### will help facilitate the 

### implementation of the 

### new Clean Air Act 

### Amendments in Alabama. I am 

### sure the Department and 

### your office will 

### continue to cooperate in managing ~labama's environmental resources.

GH :

### ch

cc: Mr. 

### Leigh PeguesPart 

### F

## -

Final Regional Haze State Implementation Plan