Paul C. Aughrry, I11 

Chairman 

BOARD: 

Henry C. Scorr 

Edwin H. Cooper, 111 

Vice Chairman 

Steven G. Kisner 

Secretary C. Earl Hunter, Commissioner 

Promotirig andprotecting the health of the public and the enuironmer~t 

M. David Mitchell, MD 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

March 14, 201 1 

Ms. Gwendolyn Keyes Fleming 

Regional Administrator 

United States Environmental Protection Agency, Region 4 

Sam Nunn Atlanta Federal Center 

61 Forsyth Street, SW 

Atlanta, Georgia 30303-8960 

Re: Revisions to the South Carolina Air Quality Implementation Plan - Prevention of Significant 

Deterioration and Nonattainment New Source Review 

Dear Ms. Fleming: 

The South Carolina Department of Health and Environmental Control ("Department") is requesting that 

the U.S. Environmental Protection Agency ("EPA") grant final approval of revisions to the Prevention of 

Significant Deterioration ("PSD") and Nonattainment New Source Review ("NSR") provisions of the 

South Carolina Air Quality Implementation Plan ("SIP"). The Department requested parallel processing 

for this revision on December 2,201 0. Under the parallel processing procedure, the EPA Regional office 

works closely with the state during the development of new or revised regulations and solicits public 

comment in approximately the same time frame that the state notices its proposed revisions and holds its 

public hearing. 

Background 

On November 29,2005, the EPA issued a final rule in the Federal Register entitled Final Rule To 

Implement the 8-Hour Ozone National Ambient Air Quality Standard (70 FR 71612), also known as the 

"Phase 2 Ozone Rule," which finalized regulations to implement the 8-hour ground-level ozone National 

Ambient Air Quality Standard that the EPA established in July 1997. The Department has implemented all 

required elements of this rule, but is clarifying a footnote to the PSD regulations to list nitrogen oxide 

(('NOX") as a precursor to ozone in this SIP revision. 

On April 25, 2008, the Department published a Notice of Drafting in the South Carolina State Register to 

initiate revisions to Regulation 61-62.5, Standard No. 7, Prevention of SigniJcant Deterioration, 

Regulation 61-62.5, Standard No. 7.1, Nonattainment New Source Review (NSR), and the SIP, in order to 

comply with a final rule entitled Prevention of SigniJicant Deterioration (PSD) and Nonattainment New 

Source Review (NSR): Removal of Vacated Elements (72 FR 32526), published in the Federal Register on 

June 13,2007. 

On May 16,2008, the EPA published a final rule in the Federal Register entitled Implementation of the 

New Source Review (NSR) Program for Particulate Matter Less Than 2.5 Micrometers (PM2.3 (73 FR 

SOUTH CAROLINA DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL 

2600 Bull Street . Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 
Ms. Fleming 

March 14,20 1 1 

Page 2 

28321), also known as the "NSR PM2.5 Implementation Rule," which finalized regulations to implement 

the NSR program for fine particulate matter (that is, particles with an aerodynamic diameter less than or 

equal to a nominal 2.5 micrometers, generally referred to as "PM2,5"). The NSR PM2.5 Implementation 

Rule became effective July 15, 2008, and required states with SIP-approved PSD programs, of which 

South Carolina is one, to submit revised PSD programs within a 3 year transition period following the date 

of its publication (May 16, 201 1). The NSR PM2.5 Implementation Rule included a major source threshold, 

significant emissions rates for direct PM2.5 and its presumed precursors, sulfur dioxide (SO2) and NOx; 

offset ratios for PM2.5; and interpollutant trading for offsets and applicability of NSR to PM2.5 precursors. 

The NSR PM2.5 Implementation Rule also continued the EPA's policy of allowing SIP-approved states to 

use PMlo (that is, particles with an aerodynamic diameter less than or equal to a nominal 10 micrometers) 

as a surrogate for PM2.5 in meeting the NSR requirements of the Clean Air Act, until the end of the 3 year 

transition period ("EPA PMlo Surrogate Policy"). 

On September 26,2008, the Department published a second Notice of Drafting in the South Carolina 

State Register for the revisions to Regulation 61-62.5, Standard No. 7, Prevention of SigniJicant 

Deterioration, Regulation 6 1-62.5, Standard No. 7.1, Nonattainment New Source Review (IVSR), and the 

SIP. This second notice incorporated, among other things, the NSR PM2.5 Implementation Rule. 

On April 24,2009, the Department published a Notice of Final Regulation in the South Carolina State 

Register to complete the regulation development process initiated by the aforementioned Notices, except 

for the revisions required to incorporate the NSR PM2.5 Implementation Rule. The Department elected to 

delay these revisions for the NSR PM2.5 Implementation Rule, pending further guidance from the EPA, 

which the EPA released in part on September 29,20 10. 

Current Revisions 

On July 23,2010, the Department published a Notice of Drafting (included as part of Appendix A) in the 

South Carolina State Register to incorporate the NSR PM2.5 Implementation Rule and the clarification 

from the Phase 2 Ozone Rule. On August 16,201 0, EPA Region 4 advised the Department not to include 

the interpollutant trading ratio amendments in the NSR PM2.5 Implementation Rule in this SIP revision, 

pending the resolution of litigation. The Department has not included interpollutant trading ratios in this 

SIP amendment. 

On October 1,201 0, per a request fiom the EPA, the Department submitted its initial prehearing SIP 

package to the EPA for review and comment. On October 8,201 0, the Department received 

recommendations fiom the EPA based on the October 1,201 0, submittal. The Department addressed these 

recommendations in an October 20, 2010, revised prehearing SIP package. 

On November 26,2010, the Department published a Notice of Proposed Regulation (included as part of 

Appendix B) seeking public comment on the current revisions to the SIP in the South Carolina State 

Register. On December 17,201 0, the EPA notified the Department that it had reviewed the October 20, 

201 0, submittal, and that it had no comments. On December 29,201 0, the Department held a staff 

informational forum ("SIF"). No stakeholders attended, and the Department received no comments during 

the comment period. A transcript of the SIF and copy of the SIF Sign-in Sheet are included as part of 

Appendix A. 
Ms. Fleming 

March 14,20 1 1 

Page 3 

The Department held a public hearing before the Board of Health and Environmental Control on February 

10, 20 1 1, at which the Department received no comments. A transcript of this meeting is included as part 

of Appendix B. On February 25,201 1, the Department published a Notice of Final Regulation (included 

as part of Appendix B) in the South Carolina State Register to revise Regulation 6 1-62.5, Standard No. 7, 

Prevention of Signzjicant Deterioration, Regulation 6 1-62.5, Standard No. 7.1, Nonattainment New Source 

Review (NSR), and the SIP. 

The Department appreciates the assistance provided by EPA Region 4 during the formulation of this plan. 

Should you or your staff have any questions or comments concerning this SIP revision, please contact Alan 

Hancock of the Bureau of Air Quality by email at hancocam@dhec.sc.gov or by telephone at 

Robert W. King, Jr., P.E. 

Deputy Commissioner 

Environmental Quality Control 

ec: Richard Schutt, Chief, Air Planning Branch, EPA Region 4 

Lynorae Benjamin, Chief, Regulatory Development Section, EPA Region 4 

Royce Dansby-Sparks, Regulatory Development Section, EPA Region 4 

Twunjala Bradley, Regulatory Development Section, EPA Region 4 

Joel Huey, Regulatory Development Section, EPA Region 4 

Myra Reece, Bureau Chief, BAQ, S.C. DHEC 

Renee Shealy, Assistant Bureau Chief, BAQ, S.C. DHEC 

Robert Brown, Director, Division of Air Assessment, Innovations, and Regulation, BAQ, 

S.C. DHEC 

Maeve S. R. Mason, Manager, Regulation & SIP Management Section, BAQ, 

S.C. DHEC 

CD enclosure: 

1. Text of Final Regulation (strikeout and clean copy) 

2. Appendix A: Notice of Drafting, Notice of Proposed Regulation, Staff-Led 

Informational Forum Sign-in Sheet and Transcript 

3. Appendix B: Board Public Hearing Transcript and Notice of Final Regulation 

4. Appendix C: Copy of Legal Authority