### NorthCarolina 

### Department

### of Environmentand 

### Natural Resources Divisionof 

### Air Quality Michael F. 

### Easley,Governor William G. Ross,

### Jr.,Secretary B. 

### Keith Overcash, P.E., 

### Director December 13,2007 Kay T. Prince Chief, Air Planning Branch USEPA Region 4 Atlanta Federal Center 

### 61 Forsyth Street, SW Atlanta, GA 30303-3104 Dear Ms.Prince: Thank you for your letterdated November 26, 

### 2007, transmitting the 

### U. S.

### Environmental Protection Agency's comments on thepre-hearingdraft ofthe Regional Haze State Implementation Plan (SIP) forNorth Carolina Class

### I areas. 

### I greatly appreciateyou and your staff taking the time to review the pre-hearing draft documentation. Enclosed with this letter is ourresponse to your comments. The North CarolinaDivision of Air Quality plans to submit its final Regional Haze 

### SIPby December 17, 2007, the statutory deadline forregional haze plans. We hope to continueto work with you and your staff in the future as we monitor the progress in the North CarolinaClass I 

### areas ofreaching natural background visibility conditions. 

### If you should have any questions, please contactLaura Boothe of my staff at 

### (919) 733-1488 or laura.boothe@ncmail.net.



### Enclosure CC: LauraBoothe Dick Schutt, USEPA Region 4 Nacosta Ward, USEPA Region 4 Michele Notarianni,USEPA Region 4

1641MailSewice Center, Raleigh, NorthCarolina 27699-1641 2728 Capital Bivd., Raleigh, North Caroiina 27604 Phone: 919-715-7670 1FAX919.715-7476 iInternet: w.ncair.org An EqualOpportunityiAfiirmativeAction Employer

### -50% Recycled/lO% Post Consumer Paper 

### One 

# NorthCarolina

### J~csponse to Comn~enls received by 

### C.S. Environmental Protection Agency (IJSEI'A) USEI'A Comment: "The Regional Hazeregulations in 40 

### CI'R 51.308(i)(3) require States to explain how they addressed the comments from the Federal Land Managers in their SIP. Please address40 CFR 51.308(i)(3) in your final subniittal." 

### NCDAQ Responscx Respoilses to the Federal Land Managers' (FLM's) comments will be iiiciuded as part orthc Jinal Iic$ional 1-IazcState lmple~ncntalion Plan (SIP) as part of Appendix S Cons~lltation l'roccss. I.IS1<13A 

### Comment: "Pages 8 and 9: 'I'lle estimation of natural background is an iinportant component 

### of the tcchnical analyses in thc Regional I-Iazc S11'. We recommend that this section bc revised (or a new subsection added) to addresstire ieclnnical manner in which ilatural background was developed for reasonable progress and for 

### BART. Currentlythese discussions are presented in appendices without being specifically refereuced inthe 

### SIP Narrative. The discussion should reference the specific data ~ised in applying the new IMPROVE equation for the reasonable progress goal determinations presented in Table 2.3-1." IVCDAQ 

### Response: Z,anguage will he added in the ha1Regional Haze SIP to address this concern 

### IJSEl'A Comment: "Pages 87and 88: We suggest a clarification to the statement repeated on pages 87 and 88 as follows (see underlined text): "Since the BART determination takes into consideration many of the samc factors asfor reasonable progress, the BART subject units were not re-evaluated in the reasonable progress review.'"' 

### NCDAQ licsponse: The sl~ggesled ianguagc will be added in the final Regional [-lazeSIP. USlWA 

### Commcnt: "Scction 7.8, Step3: '1'0 f~lrthcr strengthenthe State'sjustiiicatiou that the Clcan Air Intcrskte Rule 

### (CAR)is suflicient for reasonable progress Sor subject clcctric geilcraiiilg units (I3GUs) during the first planning period, wc suggest to also include a reSereincc to tine language in the 

### CAIR rule wlnich says, in summary,that the CARcontrols are all that arc reasol~ahle ibr the compliance period of the rule. 

### NCDAQ Response: Language will be added to the final Regional Haze SIP to address thls comment. 

### USEPA Comment: "Section 11.0and 

### 12.0:The Skate makes several statementsusing terms such as the State "commits" to talie certain actions in the iirture, several of which are actions required by the rcgioslal haze regulations. The final SIP sl~ould make it cleaif all ofthese actions are intended as mticipaied actions; which are unenforceable; or enforceable commitments. It is suggested that the Statekeep all enforceable coinmit~nents to those requirements already in the regional haze regulations and dislinguisli future aspirations w-it11alternative language. We believe such language could be worded as, '"The State [anticipates or will likely or intends] to take [describe action].

. .", similarto what was done on page 

### 11-66 under Step 3."

### IVCDAQ liesponse: The NCDAQ will rcvicw thc Language in Scction 

### 1 I 0 and 

### 12 0 and imalic the rccominend changcs 

### USEPA Comment: "Section 12.0:We suggest a clarification to the followingheader (see yndcrlined icxt) such as, "List of Possible Actions --adapted from 40 CFR 5l.30R(h)," to clarify that provisions that follow also include a fcw items not specified in 51.308(h). 

### NCDAQ liesponse: The suggested language will be addcd in the final Regional Haze SIP. 

### liSEPA Comment: "Appendix 

### 13;Section2.0Uniform Rate ol'Progress, Pagc Appendix FI-19: This section states that VISTAS plans to present "glidepath" results for both the old and new II\/Il'IIOVE equation. This data should be added or a reference to the specific location in the Appendices should be provided." 

### NCDAQ Response: A reference to Appendix 

### A will be added to this section in the final Regional Haze 

### SIP. 1JSEPA Comment: "Aipendix 11, Scction 6.3,Process of Applying Statutory Factors: Pages 

### 1-1- 69-70: 'The discussion of the reasonable progress assessment for the PCS Phosphate facility discusses the BART and Prevention of Significant Deterioration (PSI)) evaliiations for two oi'tlie four units listed in the table onPage 1-1-71. No specific discussion is to support the s~atcniciit that "l3asically, no cost effective controls werc identified for the four units at this facility." Also, the discussion in this section should be updatcd to rcflcct t11c final outcome of'the BART determination for PCS Phosphate is?Appendix 

### I>.10. 

### NCDAQ Response: Language to address this comment will be added in the final Regional Haze S11'. 

### CJSEPAComment: "H-74: In Section 8.1, the followingparagraph needs to he updated to reflect the Statehas completed itsBART determinations: "The NCDAQ is still in the process of reviewing the RAIIT determinations from the two facilities that werc determined to be subject to RAIZT.



### . ..'"' 

### NCDAQ liesponse: This will be updated in the final SIP submittal 

### USEPA Comment: "Appendix L.10, PCS Phosphate BART Pre-hearing U)eterminatioil Analysis. Page L.10-470 & Appendix 

### 13, Section 6.3, Process ofApplying Statutory Factors, l'ages 1-1.69-70: The discussion of the BART assessments for the PCS Phosphate facility should address why ainmoiiia was not evaluated as a potential "visibility impairing pollutant." TheVISTAS J3AR7' Sensitivity Analysis presented in Appendix 

### L.3 indicates that PCS Phosphate is one of the ibur large sources of ammonia emissions in the soutlleast. 'Theresults of the VISTAS modeling aidysesindicate that ainmonia en~issions from I'CS I'hosphate could contributc to a visibility impact at the Swanquarter Class I area (seepage L.3-11). 'Therationale for not evaluating ammonia emissions in the BART for PCS Phosphate should be providcd or the HART analysis should be revised to address the impacts ofthc facility's 

### ammonia emissions."

### NCDAQ licsponsc: This comment will he addressed in both Appcndix 

### I~I and 

### L by referencing thc fbllowing language in the PCS Phosphate 

### BAIIT evaluation (Appendix 

### 1..10-159): "Ammonio enzis.sionsure also minin?ized,fionzthe DAI' 

### I'luni Ilia. 

### 3 as the ,rcruhheis uue inpluce,/br/mi? 

### emissions control und,fi)rainnmnia cuplure and recjicle to iheprocess. Therefore, UART.forDAP 

### No. 3 i.sno uddiiionul conlrol, as lheplulzi is 

### alreudji well-conlrolled and uddiiionul confrolis no/ cosi @xtive3'