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 of the Alabama Department of 

Environmental Management 

Part B - Legal Notice 

Proof of Publication of Legal Notice 

Proof of Notification of Cancellation of Public Hearing 

Part C - Executive Summary 

Part D - Reconciliation Statements 

PartE - Legal Authority 

Part F - Final Regional Haze State Implementation Plan 
Part A - 

Resolution Signed by the Director of the Alabama Department of Environmental 

Management 
ALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

RESOLUTION 

WHEREAS, on March 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 of Environmental Management, as 

designated by the Director of the 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 of Environmental Management has reviewed 

the written submissions introduced into the record, and has prepared a concise statement of 

the response to comments received; and 

WHEREAS, minor changes have been made to the proposed revision to the State 

Implementation Plan pursuant to comments. 

NOW THEREFORE, as Director of the 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 state that this revision shall 

become effective immediately on the date indicated below. 
Part B - 

Legal Notice 

Proof of Publication of Legal Notice 

Proof of Notification of Cancellation of Public Hearing 
ALABAMA DEPARTMENT OF EIWIROMMIEMTfi MANAGEMENT 3\ 7 

NOTICE OF IWELPC WEARING 

FOR PROPOSED REVISIONS TO THE 

ALABAMA STATE I[HBLEMENTATHON PLAN (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 5:00 p.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 

1400 Coliseum Boulevard 

(P. 0. Box 301463, Zip code 36130-1463) 

Montgomery, AL 36 1 10-2059 

(334) 394-4360 
ADEM, Birmmgham Field Office 

Attn: Sheila Vail 

1 10 Vulcan Road 

Birmingham, AL 35209-4702 

(205) 942-6 168 

ADEM, Decatur Field Office 

Attn: Jan Childers 

27 15 Sandlin Road, SW 

Decatur, AL 35603- 1333 

(256) 353-17 13 

ADEM, Mobile Field Office 

Attn: Karmen Tolbert 

2204 Perimeter Road 

Mobile, AL 36615- 113 1 

(25 1) 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 

1 130 Quintard Avenue 

Anniston, AL 3620 1 

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 as the 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 36 110-2059) 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's Permits and Services Division at (334) 271-77 14 at least five 

working days prior to the hearing. 

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 BIRMINGHAM NEWS 

Jaoai<ir, - --oinbigbus 

Pdvers Planim & 

Developmeni &rnrnlss!on 

Courthouse Annex i 07 Broad S:reet 

Camden, AL 36726 

LETICE 3F PUBLIC 

I-IEAEliuG FOR 

PROPOSED REVISIONS 

TG THE ALABAMA 

STATE IMPLEMENTATION PLAN (Slfi 

Notice Is hereby glven that 

the Alabama Deonrfmant nf 

1:tteiested persons io reWest a public hearin and 

co~me~it on ropose61revi. 

%ow :o the .&abama State 

Implementation Plan (SIP) 

requests lor a heanng are 

'acelveo prlor lo thls date a 

"lolze of Cancallsl~nn nf thrr 

I lnteres'ed pets& I& 

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

In has been cancelled I= Afabama Department L ivlronmental Manage 

' pmposes to amend ths arna State lmalnmanta - . . . -. , .- 'I. . Van to adopt measures zddress regional haze 

'r- ,es In Alabama. The '- !F. an Alr Act requires Sraes to develop 

iz+,m plans that 

91'1: ,dl haze near Ch I ar- ecr Theplzn shtuld eddress P.?i- 

. .- ,. ng reasonable prog- v,i s a, toward establlshlng 

,a-rwres to prevenf Mure 

stic remedy any extbtlng Imi,e.:rnent of vlsiblllty In 

mandatory Federal Class I areas Whlch lmpalrment re- ;el:? from manmada air 

Ing consultatlon w~th the 

Federal Land Managers (FLMs Thls was accom- pitshed through conference 

calls, consukatlon meetings a'id rhrough an advanced 

cup\ of the SIP for revlew 

and comment Documentar~orl of the consultation 

meetings and conference 

calls can be found In 

d~x Jof the ReglonaX,"; 

SIP The comments wed 

flom the FLMs on the Drafi 

SIP are kted in Appendix F of the Reglonal Haze SIP 

Tne Department Is also - rnakmg avallable for publ~c comment a letter cleMylng a Clean Alr Act Sectlon 110 

State lmplementatlon Plan 

(SIP) 1- nib issue 13 Uk 

related to the regional haze 

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 of Jefferson, 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 

Copies ot the proposed SIP are avallable al a cost of 

3O-C-?$Epr pge at each of 

STATE OF ALABMA 

MONTGOMERY COUNTY / f 

I i \, 

' ,, !-f Before me, ,4~ !' *- I - a Notary Public - i 

I in and for the Stare and County aforesaid, penonally appeared fflfic, &L 

who, first being duly sworn according to law, deposes and says that she is the 

BOOKKEEPER for The Advertiser Company, publishers of the The Morrgomery 

Advertiser and The ProttuiNe 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 revlslons to me 

sate Imple 

mentalion Plan (SIP) 

me ~epomnent re cdves a request for a heodng, the heorlng will 

be held on Apdl23,2[8)8, at lW a.m. In the Moln 

Heattng Room at the 

ADEM - Central ORlce b 

cation at 1400 Collseum 

Blvd. In Montgcmeiv. 

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 m Lma 

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 &~ity In 

mandatory Federal 

Class I areas which Irrr 

palrment resub from 

manmode ak pouutlon. mepwposeafthbSIPre 

vislon LB to fulfRl Ws fedefa1 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 

m e at each of the 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 366151 131 

(251) 45D3400 

~wma - Tombigbee Rivers Plannlng @ 

2%EEt 

~~;ihwse Annex 

107 Brood Sh6d 

Camden. AL 36726 

East Alaborna Reglonal 

planning L Development 

Commtsslon 

1130 Qulntord Avenue ' 

AnnMm.AL 36201 1 If requested, a hearing / 

wlll be held to receive 

data vlews and argw menk hom Interested mamm reaardina he 
hhn. 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 be found In Ap pendlx J of Me Regional 

Haze SIP. The cments 

received horn the FLMS on lhe Drat7 SIP are locat. 

ed In Appendix P of Me 

Rqbnal Hore SIP 

ADEM. Moblle FM mce 

AHn: Karmen Tolbert 

views, arguments,- or COITmenk os the same may be submitted In wrtt- 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, Permits ana SewIces Dlvlslon. Nabom 

Dement of Envlronmental Mana ernent 

P.O. Box 3014651, ~ont: , AL 361?&1463 

Mont omery AL 

361 10-2859) 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 March 9,2M8. Dy 

OuthOMy Of ADEM. 

OnlS 'Trey' Glenn. ill Dlrector 

Mont. Adv. 3/9/08 

779922 
Account Number 1003427 

Per~od Ending 03110108 

LEGAL AFFIDAVIT 

Name: ADEM 

Sale Rep Laura Lenoir 

Questions Please Call (251) 219-5405 

ADEM 

PO BOX 301 463 

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 AD NUMBER DESCRIPTION SAU SIZE 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 CARLSON AT 

(251) 219-5418 YOU CAN PLACE A LEGAL NOTICE BY EMAlL OR FAX 

LEGALSGPRESS-REGISTER COM OR FAX# (251) 219-5037 

ALABAMA DEPARTMENT OF 

ENVIRONMENTAL 

MANAGEMENT 

I 

NOTICE OF PUBLIC HEARING 

FOR PROPOSED REVISIONS 

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 

deadltne to 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) 249-5405 OR (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 361 10 

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 FAO I FJight Loq I 

Search I -anization I Contents l Feedback I Related Links I MWI i Forms I Records Request / eDMR 

~e fo\lowin&es are provided in Adobe 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 

Room 
Part 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 of Alabama's Regional Haze State Implementation Plan 

Response to Comments Document 

July 2008 

Commenters: 

United States Department of the Interior's Fish and Wildlife Service received 2 1 April 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) do not appear 

on the "BART Eligible Unit List" (Attachment H.3) of the Regional Haze SIP, but 

the FWS received hard copies of their exemption modeling. Both were below the 

0.5 dv impact cutoff. It appears that they should appear on the BART Eligible Unit 

list. 

RESPONSE: The two facilities have been added to Attachment H.3 

2. The Alabama Modeling Summary (Attachment H8) of the RH SIP lacks the 

modeling results for the following facilities that appear on the 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 so that you should actually page across the 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 contradiction regarding Oak Grove Resources- JCDH in that 

the Alabama Modeling Summary (Attachment H8- Table 4-6) shows this facility to 

have a 0.02 1 dv impact when Table 7.8.4-1 of the RH SIP shows an impact of 0.535 

dv. This difference should be explained or rectified. 

RESPONSE: Initial modeling for this facility showed an impact of 0.535 dv at the Sipsey 

Wilderness Area. However, after review of the 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 0.021 dv. 

Unfortunately, Table 7.8.4-1 in the SIP Narrative was not updated. This has been 

corrected. 

BART Determination Issues 

Attachment H8 of the RH SIP contains State-developed summaries of the 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 1.0 13 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 the No. 1 Combination Boiler as if it was operating 

the entire year. 

5. A BART Control strategy involves installation of low NOx burners (LNB) on the 

#2 Combination Boiler. That table on page 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% NOx control 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 seem to 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 in NOx emissions 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 low NOx 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 of LNB and the 30% 

reduction to the permitted limit is BART. 
In order to evaluate control rates, IP modeled the No. 2 Combination Boiler at varying 

percentages of control. This modeling was intended to evaluate the magnitudes of 

improvement associated with the different control levels. The results of this modeling are 

reflected in Table 3-2 in IP's BART determination. The numbers in the table represent the 

average of the 9sth percentile concentrations across all of the receptors at the Sipsey 

Wilderness for each of the 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 Combination Boiler 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 if the No. 2 Combination 

Boiler was evaluated alone. Based on this information, the Department agrees with the 

proposed controls on the No. 2 Combination Boiler. 

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 of model sensitivity analyses conducted to investigate the 

impact of large SO2 and NOx emission reduction (i.e., up to 95% control) indicated 

relatively little effect on visibility impairment. These results suggest that the 

atmospheric transport times and chemical conversion rates of gaseous precursors 

into visibility-impairing particulate matter are too low for there to be a major Class I 

area visibility improvements." FWS believes the statement of "little effect on 

visibility impairment" is not acceptable. FWS considers the resulting deciview 

improvements particularly with the installation of wet 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 SO2 and 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 of BART 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 

SO2 controls. The recommendation regarding the installation of wet scrubbers, specifically 

for the coking boilers, is discussed in the later comment responses. 

7. Comment regarding hour limitations for Boilers #5 and #6 and the addition of wet 

scrubbers for control: Solutia, Inc. concluded that Boilers #5 and #6 should be 

limited to no more than 1800 hours of operation in a year, primarily being operated 

only when other units were not in operation; but did not consider this limit to be a 
limit as a result of BART. The FWS considers this to definitely be a BART limit. 

Solutia's analysis showed that wet scrubbers on Boilers #5 and #6 would cost about 

$1,000 per ton of SO2 and $8.9 million 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 of wet 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 sulhr coal without the addition of wet 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) for NOx (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) for NOx 

control and a wet scrubbing alternative for SO2 control 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 of the 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 deciview 
improvement 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 SO2 and NOx limits: The FWS agrees with ADEM 

that for Boiler #7 the SO2 limit 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 SO2 and 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 SO2 and 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 shutdown by 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 of controls. 

11. Comment regarding proposed language by Solutia: Solutia proposed 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 BART provided the 

reduction of SO2 and NOx 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 of BART 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 of the 

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 

5 1.308(e): "The State 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: The provisos included in Attachment H5 of Appendix 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 

less than 0.5 deciview (dv) and (2) the Florida Department of Environmental 

Protection did not request an analysis in their consultation process. 

a. We recommend that the rationale or procedures Florida uses to exempt sources, 

particularly Sanders Lead, 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 

greater than or equal to 50 (Q/d>=50), and being within 300 krn of the 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 of the 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 of Alabama chose to use the VISTAS A01 approach for identifying sources 

with impacts at the Sipsey Wilderness Area, and as a first cut for those Class I areas 

outside of the state which may be impacted by Alabama sources, we do not feel that 

a consistent approach should be 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 of Alabama will work with the state of Florida and 

EPA if the 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 of the 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 equal to 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 of the first steps taken after the list 

was created was to evaluate each unit's 2018 projected actual SO2 emissions and 

compare that to the allowable SO2 emissions for that unit. For Akzo Nobel, the 

Sulfur Recover Unit was identified initially as having a 1.54% impact on the total 

impact at the Sipsey Wilderness. During permitter review, it was determined that 

the 2018 projected SO2 emissions 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 on the 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 of the SIP Narrative, Alabama states that this facility was exempted from 

the four factor analysis because it was exempted from BART-subjectivity through a 

SO2 permit emissions limitation. If the source had undergone a BART 

determination for 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 to be subject to BART, the State will already have completed a BART 

analysis. Since the BART analysis is based, in part, on an assessment 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 RPG planning 

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 to justify 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 of the 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 

as the mechanism by which sources outside of Louisiana 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 of the state in which the 

Class I area resides to establish procedures for evaluating reasonable progress. 

Because Alabama was not contacted by Louisiana, the analysis of this source was 

not required, but rather included to provide that there will be emissions reductions 

from this source. The narrative of the SIP has been revised to include these 

discussions with Louisiana as well as to 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. Section 2.1 and 2.3: Section 2.3 of the SIP Narrative references Appendix B for 

more information on how the new IMPROVE equation is used to estimate 

natural background. However, none of the 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 errors previously provided by 

CIRA. VISTAS used the data approved by USFS. The USFS files have been added 

to Appendix B for reference and Section 2.3 of the SIP Narrative has been revised. 

2. Section 4.1.6, Summary of BASE 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 data provided in Table 4 in Appendix D.3. Please clarify 

RESPONSE: Table 4.1.6-1 in Section 4.1.6 of the narrative reflects 2002 actual 

emissions for Alabama whereas Table 4 in Appendix D.3 reflects 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 added to 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 a permit 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 on page 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. On page 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 7.8.3 has 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 a 
BART determination. Finally, as noted above, Table 7.8.3-1 has been updated to 

include information on Big Escambia Creek. 

4. St. Marks Class I Area and Step 4 of the 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 as Escambia 

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 A01 analyses, 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 201 8 SO2 percentage 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 of headquarter facilities which have several plants subject to consent 

decrees and whose reductions were modeled in the 201 8 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 as the 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 of the final permits 

where these limits are established. To prevent circumvention of the 

BART requirements, we recommend including a permit 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 

undergo NSR 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 are the 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 of this. 

c. It is unclear how the removal of all potential 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" is that it must be one of the 26 

named source categories. In the 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 potential 
emissions 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 as having an impact of 

0.535 dv, which is greater than the 0.5 dv 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 clarify and resolve the differences. 

RESPONSE: Initial modeling for this facility showed an impact of 0.535 dv at the 

Sipsey Wilderness Area. However, after review of the 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 0.02 1 dv. 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 BART provisos: 

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 of BARTsubjectivity. 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 of BART 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 5 1.308(i)(4). Section 1.6 on page 7 introduces the requirement, and 

then provides a copy of the VISTAS Memorandum of Agreement and Bylaws. 

On page 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 1.6 tying in the requirement of 

40 CFR 5 1.308(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 of the 20 percent 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 a reference to 

the SIP Narrative to the location of this 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 of this section indicated that Figure 

6.3-1 presents information for the 20 percent best days and Figure 6.3-2 presents 

information for the 20 percent worst days. However, the figures appear to be 

reversed as Figure 6.3-1 presents information on the 20 percent 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 on NO3 but the caption 

indicated it is for SO4 and 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 201 8 g4a" and "CMAQ 201 8g2b". The difference between 

these two modeling runs should be described for clarity. It is assumed that the 

"CMAQ 201 8g4a" refers to the "Best and Final" run, but this should be 

clarified. 

RESPONSE: Section 7.2.4 has been revised to include a description of the two 

runs, explaining that the difference involves different versions of the emissions 

inventory, including a statement that the CMAQ 201 8g4a run is the VISTAS Best 

and Final run. 

7. "Section 5 1.309(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 5 1.308, rather than 40 CFR 5 1.309, which applies to four 

states out West. The correct citation and language is provided here: "Section 

5 1.308(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 87 and 89: To clarify the information in the tables for 

Solutia and International Paper-Courtland Mill on pages 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 of the 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 is referred 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 of the SIP Narrative, a partial summary of the State's rationale for 

selecting the one percent is provided. A complete rationale is provided 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 5.0 has been provided in Section 

7.7 of the 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 of the 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 less than 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 SIP Narrative 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 of the SIP Narrative and in Appendix H 

have been revised to say one percent or greater, including text and tables. All of the 

tables are listed as including those sources with impacts of one 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 of Alabama 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 of the 

state which may be impacted by Alabama sources. 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. 

1 1. Affected BART Facilities: The SIP Narrative and Appendix H provide different 

numbers of BART 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 37 BART 

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 of the term 

"reasonable further progress" and "RFP" intended to mean "reasonable 

progress". 

RESPONSE: The term "reasonable fh-ther progress" 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: Since one Alabama source (TVA Widows Creek) has a 

one percent impact at the Joyce Kilmer Class I area, data should be added to 

Table 5.2 for 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 if the 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 of the two sections, or 

refer the reader in Appendix H to the SIP Narrative 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 Comments by 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 5 1.308(d)(l) makes clear that a State must establish RPGs "[flor each 

mandatory Class I Federal area located within the State." The Rule therefore requires 
Alabama to establish WGs only for the Sipsey Wilderness. SEVIC believes the source 

of this 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 of 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. It is likely that that EPA's guidance language was intended to generally 

express the expectations of the States. 

2. Page 3, 4th: ADEM states that BART requirements constitute "a specific component of 

each state's first LTS." However, the structure of the 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 of reasonable progress. 

RESPONSE: The SIP Narrative 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 on track to meet SIP forecasts, 

then states would need to take action to assure emissions controls by 201 8 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 planning period for each regional haze SIP is to achieve the 

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 does not 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 situation where "the existing implementation plan 

requires no further substantive revision at this time to achieve established goals for 

visibility improvement and emission reductions." Of course, there are no established 

goals for emissions reductions per se but only for visibility improvement. Thus, if the 

visibility improvement goals are being met at the 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 of visibility improvement. In the absence of failing 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 since the baseline date as well 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 of 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. 

5. Page 15, last: ADEM states that the "Best and Final" run incorporates 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 of the control requirement? 

RESPONSE: The term "reasonable hrther progress" 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 BART provisos. In regards to RP, for 

the 201 8 progress 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 on pages 2-3 of SIP. 
RESPONSE: It is also ADEM's interpretation that the State of 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 201 8, what pollutant reductions from what source categories could 

provide the largest amount of additional visibility improvement?" 

RESPONSE: It is ADEM's contention that the current language in the SIP Narrative 

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 201 8 emissions produce the most visibility 

improvement at the Sipsey Wilderness? 

RESPONSE: It is ADEM's contention that the current language in the SIP Narrative 

largely minors the suggested language in its intent. In both cases, the focus is on those SO2 

sources for the purposes of the 201 8 goal that, if controlled, would result in visibility 

benefits. No revision to the SIP is necessary as a result 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 of question h. 

RESPONSE: ADEM agrees and as such has changed Section 7.1 of the SIP Narrative 

accordingly. 

1 1. 5 7.1, item f: The emission controls per se representing BART are immaterial. The 

question should focus on the 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 of the question would 

ask: "After accounting for the visibility improvement achieved in Alabama's Class I 

area due to emission reductions required by other CAA programs and by 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 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. 

13. Page 54: In fact, visibility at the Sipsey Wilderness "is expected to improve to levels 

better than the glidepath by 201 8 based on reductions 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 8 based on reductions from existing and planned 

emissions controls alone." 

14. Page 59, 2nd: SEVIC is glad to see ADEM's acknowledgment that "[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 on the presumption that the magnitude of visibility impairment 

attributable to international emissions does not decrease significantly over time. SEVIC 

believes that ADEM should also recognize that the baseline's inclusion of visibility 

impairment due to international emissions injects a bias into the glidepath by 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 of this analysis are 

misleading, at best, 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 impairment by different 
pollutants 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 

on the 201 8 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 SO2 and NOX emissions after 2009, i.e., during implementation of Phase I1 

of the CAIR and other planned emission controls. Because the discussion on page 59 

states that such determinations of relative visibility impairment in 201 8 were initially 

made, SEVIC requests that those results be presented along with a discussion of why 

they were rejected in favor of impairment values obtained from using a 

nonrepresentative 2009 emission inventory. SEVIC recognizes that ADEM has briefly 

addressed this matter in section 3.0 of Appendix H ("the full benefits of controls 

anticipated by 201 8 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 201 8 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 of 201 8. We also understand from the SIPS of other VISTAS 

States that the determination of pollutants' relative impairment to visibility was based 

on modeling results from only a few days. If that is the case, then SEVIC requests 

ADEM to comment on whether that limited data set for the contribution analysis was 

sufficiently large to provide statistically representative values for those relative 

impairment levels. Clearly, as emissions of SO2 and NOX decrease substantially from 

2009 to 201 8 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 201 8 attributable to other pollutants should be 

greater than what ADEM has reported. 
RESPONSE: From the IMPROVE monitoring data, the speciated contributions to light 

extinction on the 20% worst visibility days at Sipsey clearly demonstrate that sulfate is the 

dominant pollutant of concern. 

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 in NOx and carbon were small in comparison. These 

results were not used in the SIP because the 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 20 18 inventories 

were comparable and indicate that the states would see the greatest visibility benefits from 

reducing SO2 from EGU and non-EGU sources within the same state as the Class I area and 

neighboring states. SOz emissions from EGUs will be reduced between 2009 and 201 8; 

therefore the absolute magnitude of response to further SO2 reductions from EGU would be 

smaller in 201 8 than in 2009. SO2 emissions from non-EGU point sources are projected to 

increase slightly between 2009 and 20 18, therefore the non-EGU responses shown for 2009 

are likely representative of responses in 201 8. The conclusion that further SO2 reductions 

from EGU and non-EGU sources will be most important remains valid whether 2009 or 

20 18 inventory 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 201 8 

16. 5 7.5, Relative Contributions to Visibility Impairment: Geographic Areas of Influence 

(AOI) at Class I Areas Affected by Alabama Sources: One objective of this analysis 

was to identify the Area of Influence for Sipsey Wilderness, i.e., the specific geographic 

area containing the point source SO2 emissions that most likely influence visibility at 

that Class I area. Once such an area was defined, the second objective of this analysis 

was to identify specific SO2 emission sources in that area that would be candidates for 

control measures to achieve reasonable progress in the Sipsey Wilderness. SEVIC 

believes that some of those candidates for reasonable progress controls could have been 

inappropriately identified as such due to the questionable method for defining Sipsey's 

area of influence. ADEM states at page 67 that Sipsey's "A01 was defined as the 

counties with maximum sulfate extinction weighted residence time greater than 5%." 

That analysis consisted of first plotting residence time using five years of back 

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 

of influence was determined solely on visibility levels at Sipsey dominated by sulfate 

during 2000-2004. Once that geographic area was defined, candidate sources for 

"reasonable progress controls" were then identified. SEVIC believes the analysis to 

define Sipsey's area of influence is flawed because it was based on the wrong data, i.e., 

visibility levels due to SO2 emissions during 2000-2004. Major SO2 emission reductions 

will occur between 2004 and 201 8 due to 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 SO2 emissions had the greatest 

residual contribution to the area in 201 8 and then accounting within each category for 

the SO2 reductions 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 SO2 emissions during 2000-2004. In effect, 

VISTAS'IADEM's "adjustment" was made to the wrong population of SO2 sources. 

SEVIC believes that an appropriate area of influence for Sipsey would have been based 

on 201 8 SO2 emissions projected to remain after implementation of all existing and 

planned SO2 controls. The SO2 sources 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 SO2 emissions 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 201 8 

emissions, 

2) Q/d 35 using 20 1 8 emissions, and 

3) 201 8 emissions 2 250 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 

surrounding how 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. fj 7491(g)(l). In that context, the statutory term "progress' is 
nothing more than a synonym for "visibility improvement." Black-letter law holds that 

when the provisions of a regulation (the Rule) conflict with the provisions of its 

underlying statute (the CAA), the provisions of the statute must prevail. Thus, 

regardless of ADEM's understanding of what 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 a particular control measure is 

reasonable. Moreover, the so-called "four-factor analysis" is a gross misnomer that 

masks the importance of visibility 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 of ADEM's reasonable progress analyses in 

its draft SIP is not material in this particular instance due to the substantial reasonable 

progress which will be achieved at Sipsey by 201 8 due to other existing and planned 

CAA programs. Because the total of those visibility improvements from other programs 

is already greater than what could be achieved with Sipsey's uniform rate of progress 

(visibility improvement), the State would be hard-pressed to find any further visibility 

improvement, in the context of the 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 of what 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 of the 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 be justified 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 of the statutory factors on pages 76-77 as 

providing no support to any reasonable progress assessment for a particular 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 of the 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 $/ton value that 
EPA has concluded is "reasonable." Those costs reflect absolutely nothing about the 

relevant objective of the 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 of visibility 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 analysis was 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 SO2 and NOx. 

RESPONSE: The monitoring data and the 2009 and 2018 emissions sensitivities and air 

quality modeling results clearly indicate that SO2 reductions 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 analysis for an entire subcategory of sources is 

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 SO2 for the first 

planning period ending in 201 8." 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 CAR would 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 of the remaining three examples involves setting a 

cutoff as a percentage of a fixed value, and thus the magnitude of that cut-off value is 

fixed. By comparison, the magnitude of ADEM's 1% cut-off value for visibility 

impairment will vary as a function of the total visibility impairment in each Class I area. 

Thus, a source's magnitude of visibility 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 a reasonable progress analysis for the 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 of reasonable progress candidates based on 

VISTAS'/ADEMYs 1% cutoff approach does not satisfy that expectation. In sum, 

selecting sources having a visibility 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 states to 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 de minimis cost threshold of 

$2,000 per ton of SO2 is 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 SEVIC has noted earlier, due to the substantial amount of reasonable 

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 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. 

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 evaluate the applicability of BART to certain sources 

that were no older than 15 years old. The fact that the States are now evaluating older 

sources for BART applicability is due to the 30-year delay in responding to that 

statutory requirement. In this regard, SEVIC believes that VISTAS'IADEM's pattern of 

attributing many of the regional haze requirements to EPA's direction inappropriately 

downplays the importance of the actual direction by Congress. Many of the regional 

haze requirements for States flow directly from statutory language within sections 169A 

and 169B of the 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, SEVIC believes that concept seems to have 

been replaced throughout much of the regional haze planning process by the States 

responding instead to EPA direction that at times conflicts with the Act's requirements. 

RESPONSE: Section 7.8 of the 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 address visibility impacts. The Narrative continues by 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 and NH3 are each a 

"visibility-impairing pollutant," and no amount of modeling can change that. However, 

SEVIC understands that VISTAS modeling did show that 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 of NH3 in the State are roughly 30 times greater than those from point 

sources. 

RESPONSE: Section 7.8.2 of the SIP Narrative has been revised to state that ADEM and 

VISTAS have determined that point source emissions of VOCs do not contribute to 

visibility impairment at Class I areas within the VISTAS region. 

25. Page 83, 2nd: The first sentence misrepresents the BART liability of certain sources. For 

a stationary source to be subject to BART, the statute requires, among other things, that 
it "emits any air pollutant which may reasonably be anticipated to cause or contribute to 

any impairment of visibility in any [Class I] area." 42 U.S.C. tj 7491(b)(2)(A). Thus, if 

it can be shown that a source does not cause or contribute to 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 Guidelines reaffirmed 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 of Alabama chose to 

consider exempting some or all of their BART eligible sources from review through an 

individual source attribution approach which is believed to be consistent with 40 CFR 

5 1.308(e)(l)(ii). The first step in determining whether sources cause or contribute to 

visibility impairment for purposes of BART was to establish a threshold against which 

visibility impact is measured. The Guidelines afforded states with latitude in choosing that 

threshold, stating "Because circumstances will vary in different locations, we believe that 

States should have discretion to set an appropriate threshold depending on the facts of the 

situation. We believe, however, that it would be df$cult for a State to justifi a threshold 

higher than 0.5 deciviews. " 70 FR 39121. For this reason, the State retained 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 on the last paragraph of page 3 of this SIP, ADEM must take care not to let 

emission reductions be viewed as a surrogate for visibility improvement. Simply put, 

the success of the SIP should be measured in terms of visibility improvement. 

RESPONSE: ADEM agrees that the midpoint review conducted in 2012 (and again in 

201 8) should include an evaluation of both the emissions since the baseline date as well as 

the visibility improvement to date to demonstrate progress towards the visibility goals. 
Part E - 

Legal Authority 

March 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 Pegues 
Part F - 

Final Regional Haze State Implementation Plan