STATE OF TENNESSEE 

DEPARTMENT OF ENVIRONMENT AND CONSERVATION 

Air Pollution Control Division 

Floor, Annex, 401 Church Street, Nashville, 

May 1,2012 

Gwendolyn Keyes Fleming 

Regional Administrator 

USEPA, Region IV 

Sam Nunn Atlanta Federal Center, 12'" Floor 

b 1 Forsyth Street, SW 

Atlanta, GA 30303 

RE: TDEC July 29, 201 1 SIP Submittal, 2008 PM2.5 Implementation 

Dear Ms. Fleming: 

On July 29,201 1, the Tennessee Division of Air Pollution Control (TDAPC) submitted a SIP 

revision to EPA amending its SIP to adopt the NSR requirements promulgated in the NSR 

PM2.5 Rule, including the condensable provisions at 40 CFR 5 1.166(b)(49)(vi), to comply with 

federal regulations. These provisions are found at 1200-03-09-.0 1 (4)(b)47(vi) in our regulations 

and were state effective June 27, 201 1. On March 16, 2012, EPA proposed to revise their 

regulations because the inclusion of condensable PM fraction of primary PM was made in error. 

We will revise our regulations to be consistent with the revised federal regulations for the portion 

of the definition of regulated NSR pollutant by removing the requirement for inclusion of the 

condensable component of particulate matter emissions in (coarse) particulate matter and will 

inform you when that action has been taken. TDAPC hereby requests that EPA not approve the 

tenn "Particulate matter emissions" into the TDAPC SIP when taking action to approve the July 

29, 201 1 submittal. TDAPC will submit at a later date a SIP revision to EPA to remove the term 

"particulate matter emissions" from the definition of regulated NSR pollutant. The current 

submittal reads as follows: 

(vi) Particulate matter (PM) emissions, PM2.5 emissions, and PM 10 emissions shall 

include gaseous emissions from a source or activity which condense to form particulate 

matter at ambient temperatures. On or after January 1,201 1. such condensable particulate 

matter shall be accounted for in applicability determinations and in establishing 

emissions limitations for PM, PM2.5. and PMlO in PSD pesmits. Compliance with 

emissions limitations for PM, PM2.5, and PMlO issued prior to this date shall not be 

based on condensable particulate matter unless required by the terms and conditions of 

the permit or the applicable implementation plan. Applicability determinations made 

prior to this date without accounting for condensable particulate matter shall not be 

considered in violation of this paragraph unless the applicable implementation plan 

required condensable particulate inatter to be included. 
r ,* t ' 

Gwendolyn Keyes Fleming 

May I, 2012 

Page 2 of 3 

TDAPC asks that you exclude the underlined portions of this subpart from approval as follows: 

(vi) Particulate matter (PM) emissions, PM2.5 emissions, and PMlO emissions shall 

include gaseous emissions from a source or activity which condense to form particulate 

matter at ambient temperatures. On or after January I, 20 1 1, such condensable particulate 

matter shall be accounted for in applicability determinations and in establishing 

emissions limitations for PM, PM2.5, and PM 10 in PSD permits. Compliance with 

emissions limitations for PM, PM2.5, and PM10 issued prior to this date shall not be 

based on condensable particulate matter unless required by the terms and conditions of 

the permit or the applicable implementation plan. Applicability determinations made 

prior to this date without accounting for condensable particulate matter shall not be 

considered in violation of this paragraph unless the applicable implementation plan 

required condensable particulate matter to be included. 

Sincerely, 

QOr Barry R. Stephens, P.E. 

Director 

Division of Air Pollution Control 

Enclosure: July 29,20 1 1 Transmittal Letter 

Copy to w/enclosures: 

Stan Meiburg, EPA Region 4 

Beverly Banister. EPA Region IV 

Scott R. Davis, EPA Region IV 

Lynorae Benjamin, EPA Regon IV 
* . . Gwendolyn Keyes Fleming 

May 1,2012 

Page 3 of 3 

STATE OF TENNESSEE 

DEPARTMENT OF ENVIRONMENT AND CONSERVATION 

DMSION OF AIR POLLUTIOK CONTROL 

9TH FI OOR L & C ANNEX 

401 CHURCH STREET 

NMHVTI LE, 1%- 37243-1 53 1 

Certified Hail 

X70063450000390914463 

Return Receipt Requested 

Mrs. Gwendolyn Keqs Fleming 

Regional Admnistrator 

U. S. EPA, Region W 

Atlanta Federal Center, 12'h~loor 

61 Forsych Street, S.W. 

Atlanta, Georgia 30303-8960 

Subject: Official Submittal Request for State hplmentation Plan Revisions to de 1200-03-09-.01 Construction 

Petmits. The majority of the proposed changes are required by the final mle pertaining to Implementation 

of the hTew Source Review (NSR) Fropm for Particulate Matter Less Than 2.5 Micrometers @WZ.5), 

rvhich was published in the FederdHegister on May 16,2008. 

Dear Mrs. Fleming: 

This is an oficial submiftd request for incorporation into the State Implementation Plan of revisions to rule 1700- 

03-09-.O1 Cons(rudion Permits. The majority of the proposed changs are required by the final rule pertaining to 

Imphinmtaiion of the New Source Review @EX) Program for Paniculatc Matter Less Tban 2.5 Micrometers 

[PM2.5), which was published in the Fe'edernlRegisier on May 16,2008. 

As required one copy is iucluded with supporting documentation consisting of a certification of a State effwtive cupy 

of Chapter 1200-03-09 with the rule included as State effective. A Board order adopting the rule change, o 

Regulatory Flexibility Addendum, a Impact on Local Governments, Additional Information Required by Joint 

Govemeut Operations Committee. and evidence of a public hearing with notices and colments. Also inchrdzd is a 

compact disk containing the documents in Microsoft word and a hard copy of tbe rule showing the language change 

indicated by the striketkrwgh and redline marks. 

The Environmental Pmtwtion Agency is requested to process the enclosed material as part of the federally approved 

Shtc Implemenration Plan. 

If you need further idbrmation or documentaaon please contact MalcolmButler at (615) 532-0600 

Sincerely, 

, ' BarryRStephen4,P.E. 

Z Technical Secretary h Tennessee Air Pollution Control Bowd 

Enclosures 

cc: Mr. R Scott Davis, Branch Chief