STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENTAND CONSERVATION Air Pollution Control Division Floor, Annex, 401Church 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 29,2011, 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 ofprimary PM was made in error. We will revise our regulations to be consistent with the revised federal regulations for the portion of the definition ofregulated NSR pollutant by removing the requirement for inclusion of the condensable component ofparticulate 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 ofregulated 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 1,2011. 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 ofthis 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, 201 1, 

### such condensable particulate matter shall be accounted for in applicability determinations and in establishing emissions limitations for 

### PM,PM2.5, and PM 10in 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 ofthis 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 29,201

### 1Transmittal 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 

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STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENTAND CONSERVATION DMSIONOFAIR POLLUTIOK CONTROL 9TH FI OOR L & CANNEX

401 CHURCH STREET NMHVTI LE, 1%- 37243-1531 CertifiedHail X70063450000390914463 ReturnReceipt Requested

Mrs. GwendolynKeqsFleming RegionalAdmnistrator 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 de1200-03-09-.01Construction Petmits. The majority of the proposed changes are required by the final mle pertaining to Implementation of the hTewSource Review (NSR) Fropm for Particulate Matter Less Than 2.5 Micrometers @WZ.5), rvhichwas published in the FederdHegister onMay 16,2008. DearMrs. 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 theFe'edernlRegisier onMay 16,2008.
As required one copy is iucludedwith supporting documentation consistingof a certificationof a Stateeffwtive 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 OperationsCommittee. and evidence of a public hearing with notices and colments. Also inchrdzd is a compact disk containing the documentsin Microsoft word and a hard copy of tbe rule showingthe languagechange indicated by the striketkrwgh andredline marks.
The EnvironmentalPmtwtion Agency is requested to process the enclosed material as part of the federally approved ShtcImplemenration Plan. Ifyou need furtheridbrmation ordocumentaaonplease contact MalcolmButler at (615) 532-0600 Sincerely,



### , ' BarryRStephen4,P.E.

Z Technical Secretary 

## h TennesseeAirPollution ControlBowd Enclosures cc: Mr. R Scott Davis,Branch Chief