STATEOFTENNESSEE 

DEPARTMENT OF ENVIRONMENT AND CONSERI 

DIVISION OF AIR POLLUTION CONTROL 

gTH FLOOR L & C ANNEX 

401 CHURCH STREET 

NASHVILLE, TENNESSEE 37243-1 531 

April 4,2008 

The Honorable James I. Palmer 

Regional Administrator 

United States Environmental 

Protection Agency 

Region 4 

Atlanta Federal Center 

6 1 Forsyth Street 

Atlanta, Georgia 30303-8960 

Re: Clean Air Act - Tennessee Regional Haze SIP 

Dear Mr. Palmer: 

I am pleased to officially submit the state of Tennessee's Regional Haze SIP to the United 

States Environmental Protection Agency for federal review, approval and incorporation 

into the federally approved SIP for Tennessee. 

Enclosed you will find a hard copy narrative of the SIP, a CD of all the Appendices and 

Order Number 08-003 of the Tennessee Air Pollution Control Board issued on April 4, 

2008. 

Technical inquires may be directed to Quincy Styke 111, Haidar Al-Rawi or myself at 

(61 5) 532-0554. 

&&or 

Division of Air Pollution Control 

Copy to: 

Dick Schutt, USEPA Region IV Air Program 

Michele Notariami, USEPA Region lV Air Program 

STATE OF TENNESSEE 

AIR POLLUTION CONTROL BOARD 

IN THE MATTER OF: ? 

1 

State implementation Plan Approval ) 

Regional Haze - Class I Area Visibility Impairment ) 

ORDER NO. 08-003 

BOARDORDER 

The Board finds that Tennessee is required to submit a state implementation plan (SIP) to 

the United States Environmental Protection Agency (USEPA) that addresses the 

protection and improvement of visibility in Class I areas that may be significantly 

impacted by visibility impairing emissions fiom Tennessee. The USEPA enacted 

regulations detailing this requirement fiom its statutory mandate under sections 169A, 

169B, and 1 lO(a)(2)(J) of the Clean Air Act. Those regulations are specified at 40 CFR 

51.308. 

As authorized by the Board, Tennessee participated in a regional planning organization of 

ten southeastern states known as VISTAS (Visibility Improvement State and Tribal 

Association of the Southeast). The mission of VISTAS was to prepare the science 

component of the SIP that establishes baselines and demonstrates that certain goals and 

deadlines required by federal regional haze regulations are likely to be met. 

On April 4, 2008, the regional haze SIP prepared by the Tennessee Department of 

Environment and Conservation's Division of Air Pollution Control (staff) was presented 

to the Board for frnal review, adoption and forwarding to the USEPA with a request for 

federal approval. Among other things, the Board was provided the pubIic comments 

received in regard to the SIP and a staff prepared comment summary of two public 

participation hearings relative to the regional haze SIP. I 

The Board finds that the staff has conferred with the federal land managers administering 

Class I areas that may be impacted by visibility impairing pollutants fiom Tennessee. 

The Board also recognizes that the Tennessee Regional Haze SIP includes four sourcespecific SIP revision permits that establish BART (Best Available Retrofit Technology), 

a program to require source specific emission limits for certain existing major sources 

that emit visibility impairing pollutants. The Board understands that these permits 

contain only conditions that relate to BART and that upon federal approval, the source 

specific permit will be incorporated into the source's major source operating permit 

consistent with the reopening provisions under Tennessee Rule 1200-3-9-.02(11) that 

corresponds to federal regulations at 40 CFR Part 70. 
While there are four BART permits in the Tennessee Regional Haze SIP that have been 

issued by the Board's Technical Secretary, the Board recognizes that the permit for one 

BART source - the Dupont facility in Old Hickory, Davidson County, Tennessee, will be 

ultimately incorporated into a major source operating permit issued by the Metropolitan 

Davidson County Department of Public Health. That local government agency operates 

under a TCA 68-201 -1 15 Certificate of Exemption previously issued by the Board. Until 

that local government action occurs, the Board instructs the staff to enforce the permit as 

one of its own. 

Upon recommendation by the staff for approval, the Board adopts the Tennessee 

Regional Haze SIP for incorporation into the Tennessee State Implementation Plan and 

formally requests the USEPA to approve it as part of the federally approved SIP for 

Tennessee. 

Entered and approved on this the fourth day of April, 2008 by the following Board 

members: