Company issued May 9, 2012) to U. S. EPA for adoption into Tennessee

s Regional Hazc State Implementation 

Plan. We have worked closely with your staff throughout the process and greatly appreciate their timely efforts and 

consideration regarding this matter. 

A hard copy of the SIP submittal is enclosed with supporting documentation. and the following page lists specific 

documents included with this submittal. If you have any questions or comments concerning the enclosed materials. 

please contact Quincy Styke I11 at (6 15) 532-0562, or Ouincv.Stvke@dn.zov . 

Sincerelv. 

Director 

Division of Air Pollution Control 

Enclosures 

Cc via Email: Beverly Banister, EPA Region IV 

Lynorae Benjamin, EPA Region IV 

David Baron, Earth Justice 

Patricia Brewer, DOI, NPS-ARD 

Stephen Gossett, Eastman Chemical Company 

Eastman Chemical Company - Tennessee Operations 

Prepared by 

Tennessee Department of Environment and Conservation 

Division of Air Pollution Control 

April 4,2012 

--- - - 

Alternative BART Determination 

Eastman Chemlcal Company-TN Operations 

Regional Haze SIP for TN Class I Areas 

Appendix L.13-2 

April 4, 2012 
40 CFR 51.308(e)(2) establishes criteria that must be satisfied to prove the greater reasonable 

progress requirement and obtain federal approval of the alternative BART measure at the 

Powerhouse 6-253. 

The first criteria at 40 CFR 51.308(e)(2)(i)(A) requires a list of all BART-eligible sources within 

Tennessee. This listing may be viewed at Appendix L of the Tennessee Regional Haze SIP and it 

is also presented as follows: 

Alternative BART Determination Appendix L.13-4 

Eastman Chemical Company-TN Operations 

Regional Haze SIP for TN Class I Areas 

April 4, 2012 
-- 

Alternative BART DeZermination Appendix L.13.3 

Eastman Chemical Company-TN Operations 

Regional Haze SIP for TN Class 1 Areas 

April 4. 2012 
Figure 2- TN BART Eligible Sources and Class I Areas 

,. -mumnim . . . ,.. 

IYM)VE 

--- 

12 am 

BAAT Subject Sourcesh 

IMPROVE Equ. 

9 Alcoe - Swth Plant 

10 DuPont - Old Hlckory 

11 Eastman Chemical 

BART sub'b=Cl sOurwo'r- / 12 lTV~-~tnnbsrland Fast 

IMPROVE Equ. 

Alternative BART Determination Appendix L.13-5 

Eastman Chemical Company-TN Operations 

Regional Haze SIP for TN Class I Areas 

April 4, 2012 
) acagg Copoatooeca (C) 

12) PCS Nitrogen 

13) Tennessee Valley Authority (WA) - Bull Run Fossil Plant 

14) Tennessee Valley Authority (TVA) - Cumberland Fossil Plant 

15) Zinifex 

16) Weyerhaeuser Corporation (now Domtar Paper Company) - Sullivan County 

Tennessee initially identified the above sixteen (16) facilities as BART-eligible sources. Since the 

time that the BART-eligible sources were identified, Liberty Fibers Corporation has permanently 

shut down, and the BART-eligible boilers located at the facility have been dismantled. 

Additionally, Inter-trade Holdings, Inc. has permanently shut down the acid plant that was 

determined to be BART-eligible (a reduction of sulfur dioxide of approximately 374 tons per 

year). Holston Army Ammunition Plant has requested a permit limit of 249 tons per year for 

the emissions units that make up their acid plant The Division of Air Pollution Control issued a 

federally enforceable permit restricting the acid plant emissions to 249 tons per year on 

February 25, 2008 (See Appendix L-12, pages 3-4). The subject acid plant consists of eight 

sources, with combined potential emissions of 638.2 tons of nitrogen oxides (NOx) before the 

issuance of the federally enforceable permit. However, this part of the facility has not been 

operated since 1997. The remaining sources with potential emissions above 250 TPY at this 

Alternative BART Determination Appendix L.13-6 

Eastman Chemical Campany-TN Operations 

Regional Haze SIP for TN Class 1 Areas 

April 4, 2012 
9) PCS Nitrogen 

10) Tennessee Valley Authority (TVA) - Bull Run Fossil Plant 

11) Tennessee Valley Authority (TVA) - Cumberland Fossil Plant 

12) Zinifex 

A spreadsheet of Tennessee's BART-eligible source emissions is included as Appendix L-2. A 

spreadsheet of TN's BART-eligible sources1S02 emissions and distance to Class I areas is 

included as Appendix L-3. 

TN BART-eligible sources were presumed to be subject to BART but were provided the 

opportunity to submit modeling demonstrations showing that they did not contribute to 

visibility impairment, i.e., had less than 0.5 deciviews (dv) impact, on any Class I area within 300 

km and thus could be exempt. 

40 CFR 51.308(e)(2)(i)(B) requires a list of all BART-eligible sources and all BART source 

categories covered by the program. The alternative BART being established under this action 

only pertains to the five boilers at Eastman's 8-253 Powerhouse. It does not establish a trading 

program within the meaning of the federal BART regulations. As mentioned previously, the 

state of Tennessee is establishing a source specific permit limitation in its Regional Haze SIP that 

applies only to the five boilers at Eastman's 8-253 Powerhouse. No other BART eligible facility 

will be subject to this alternative BART control measure. While EPA has not yet taken final 

- - - - 

Alternative BART Determination Appendix L.13-7 

Eastman Chemical Company-TN Operations 

Regional Haze SIP for TN Class I Areas 

April 4, 2012 
40 CFR 308(e)(2)(i)(D) requires an analysis of the projected emission reductions achievable 

through the trading program or other alternative measure. As mentioned previously, this action 

is viewed as an alternative measure in that no trading with other sources is involved. 

The table below compares emission rates of sulfur oxides under each path - BART vs. 

alternative BART- achieved by July 31,2018, the end of the first long-term strategy period for 

regional haze. 

Table 1- BART versus Alternative BART SO2 Emission Limits 

I Sulfur dioxide emission rate 

I (Natural Gas Conversion) I I 'I' If chosen by Eastman, BART must be installed and operated by April 30, 2017. 

(2) If chosen by Eastman, Alternative BART must be installed and operated by July 31, 2018. 

 BART(^) 

(post-combustion SO2 Controls) 

Alternative BART(*) 

Table 2 below compares projected emission reductions of sulfur oxides under each path - BART 

vs. alternative BART. 

(Ib/mmBtu) 

0.2 Ib/mmBtu heat input or 92 percent 

reduction, whichever is less stringent 

0.0006 Ib/mmBtu heat input 

Alternative BART ~etermination Appendix L.13-8 

Eastman Chemical Company-TN Operations 

Regional Haze SIP for TN Class I Areas 

April 4, 2012 
40 CFR 308(e)(2)(i)(E) requires a determination under paragraph (e)(3) of the section or 

otherwise based on the clear weight of evidence that the alternative measure achieves greater 

reasonable progress than would be achieved through the installation and operation of BART at 

the covered sources. 40 CFR 51.308(e)(3) outlines an option for a more simplistic 

demonstration of the adequacy of an alternative BART control measure. Essentially: 

If there is no geographic redistribution of BART eligible source emissions from a 

previously demonstrated BART modeling analysis, and 

If the alternative BART measure results in greater emissions reductions: 

Then the alternative BART measure may be deemed to achieve greater reasonable progress. 

There is no geographic redistribution of emissions under the alternate BART measure for the 

Eastman B-253 Powerhouse. The five boilers there were the subject of a modeling 

demonstration in the Tennessee Regional Haze SIP. There is no trading program involved, so 

there should be no need for additional modeling demonstrations at the impacted Class I areas. 

Additionally, Table 2 above clearly demonstrates that the emission reductions are much more 

under alternative BART as opposed to BART. Tennessee therefore declares that these two tests 

are satisfied and prove that the alternative BART for the Eastman B-253 Powerhouse result in 

"greater reasonable progress" within the meaning of the federal regional haze rules. 

Alternative BART Determination Appendix L.13-9 

Eastman Chemical Company-TN Operations 

Regional Haze SIP for TN Class I Areas 

April 4, 2012 
40 CFR 51.308(e)(2)(v) allows Tennessee the option of providing a geographic enhancement to 

the alternative BART measure. As the re-powering of the five boilers at Eastman's 8-253 

Powerhouse applies only to those boilers, does not involve trading and provides such significant 

reductions of visibility impairing sulfur oxides, geographic enhancements are not needed. As 

such, Tennessee declines this option. 

Alternative BART Determination Appendix L.13-10 

Eastman Chemical Company-TN Operations April 4, 2012 

Regional Haze SIP for TN Class I Areas 
Alternative BART Determination Appendix L.13-11 

Eastman Chemical Company-TN Operations April 4, 2012 

Regional Haze SIP for TN Class I Areas 
BART 

The holder of this permit shall comply with the conditions contained in this permit as well as all applicable 

provisions of the Tennessee Air Pollution Control Regulations. 

CONDITIONS: 

In accordance with the requirements of 40 CFR 51.308 (BART), the following emission limitation is 

established: 

Sulhr dioxide (SO?) emissions from Boilers 25-29 shall comply with the less stringent of the following 

limits: 

(a) 0.20 pounds of SO2 per million British Thermal Units (Ib!MMBtu) of heat input; or 

Reduce uncontrolled SO2 emissions by 92%. 

Compliance with these emission limits shall be determined on a thirty (30) calendar day rolling average 

basis as the average emission rate, or average SO2 reduction, from either each boiler individually while 

combusting coal, or averaged across all of the boilers that are combusting coal. 

(conditions continued on next pages) 

TECHNICAL SECRETARY 

No Authority is Granted by this Pem~ito Operate, Construct, or Maintain any Installation in Violation of any Law, 

Statute, Code, Ordinance, Rule, or Regulation of the State of Tennessee or any of its Political Subdivisions. 

NON-TRANSFERABLE 

CN-0827 (Rev. 9-92) 

POSI' Al' INSI'A1,LATION ADDKESS 

RDA- 1298 

Alternative BART Determination 

Eastman Chemical Company-TN Operations 

Regional Haze SIP for TN Class I Areas 

Appendix L.13-12 

April 4, 2012 
Monitorinc~ Plan: Monitoring shall be conducted as specified in an approved site-specific monitoring plan. 

The monitoring plan must be submitted to the Technical Secretary at least ninety (90) days prior to the startup 

of the control device. 

Recordkee~inr: All records required to demonstrate compliance with this condition shall be maintained at the 

source location and kept available for inspection by the Technical Secretary or his representative. Records 

shall be maintained for five (5) years. 

Compliance Schedule: Except as otherwise allowed by Condition 4 of this permit, Eastman Chemical 

Company shall comply with Conditions 1 and 2 of this permit no later than April 30,2017. 

Alternative BART Requirements: In lieu of complying with BART as specified in Conditions 1,2, and 

3 of this permit, the permittee may choose to implement Alternative BART, as follows: 

(a) The permittee shall submit written quarterly progress reports to the Technical Secretary and to the 

U. S. Environmental Protection Agency (EPA), Region 4 Office. The initial report shall be 

submitted no later than July 1, 2012. Subsequent reports shall be submitted within one calendar 

quarter of the previous report. 

The reports shall summarize the pennittee's acquisition of site-specific meteorological 

data at the permittee's Kingsport Meadowview site and the modeling results obtained 

from the data. Only the modeling analyses that are used to determine whether the BART 

requirements specified in Conditions 1 and 2 of this permit will be sufficient to attain 

and maintain the one hour sulfur dioxide NAAQS need be addressed in the submittals. If 

the permittee concludes that compliance with Conditions 1 and 2 of this permit are not 

sufficient to demonstrate attainment and maintenance of the one hour sulfur dioxide 

NAAQS, the permittee shall include summaries of modeling results showing the 

predicted ambient impacts of repowering the B-253 Powerhouse to natural gas (and other 

Alternative BART Determination Appendix L.13-13 

Eastman Chemical Company-TN Operations 

Regional Haze SIP for TN Class I Areas 

April 4, 2012 
(ii) July 31, 2018 

This permit contains requirements that Eastman Chemical Company must meet in addition to the 

requirements of Title V Operating Permit 557888. 

This permit shall remain valid until Title V Operating Permit 557888 is reopened to include the requirements 

of this permit. 

(end of conditions) 

Alternative BART Determination Appendix L.13-14 

Eastman Chemical Company-TN Operations April 4, 2012 

Regional Haze SIP for TN Class I Areas 
Alternative BART Determination Appendix L.13-15 

Eastman Chemical Company-TN Operations 

Regional Haze SIP for TN Class I Areas 

April 4, 2012 
Mr. Quincy Styke at (61 5) 532-0562. Copies of documents concerning these matters are 

available for review at the office of the Technical Secretary and at certain public depositories. 

For information about reviewing these documents, please contact Mr. Malcolm Butler, 91h Floor, 

L & C Annex, 401 Church Street, Nashville, TN 37243-1531, telephone (615) 532-0600. 

Summary of Proposed Change 

Regional haze is fine particle pollution that impairs visibility over a large region including Class I areas such as 

national parks and wilderness areas. Sources of haze-fonning emissions include coal-fired power plants, industrial 

boilers, and mobile source emissions. U. S. EPA's regional haze rule requim states to demonstrate reasonable 

progress toward meeting the national goal of a return to natural visibility conditions by 2064. The rule directs states 

to show a uniform rate of progress toward natural conditions for each Class 1 area in Tennessee and for certain areas 

in other states. 

Regional Haze State Implementation Plans (SIPS) must include an assessment of baseline visibility conditions 

and a monitoring strategy for measuring, characterizing, and reporting of regional haze visibility 

impairment. States must also consider ongoing control programs, measures to mitigate construction activities, 

source retirement and replacement schednles, smoke management programs for agriculture and forestry, 

and enforceability of specific measures. 

This will be the third public hearing for Tennessee's RegionalHaze SIP, and this hearing is limited to the 

proposed changed to the Best Available Retrofit Technology (BART) requirements for Powerhouse B-253 at 

Eastman Chemical Company in Kingsport, Tennessee. The proposed revisions provide Eastman Chemical 

Company the option to repower this powerhouse from coal to natural gas if it is determined to be necessary 

to comply with other federal requirements. At both Class I areas in Tennessee, visibility improvements on the 

worst days are expected to be better than the uniform rate of progress glide path by 2018 based solely on 

reductions from existing and planned emissions controls. 

Alternative BART Detetmlnation Appendix L.13-16 

Eastman Chemical Company-TN Operations 

Regional Haze SIP for TN Class I Areas 

April 4, 2012 
Air Pollution Control Division 

Nashville EFO 

71 1 R. S. Gass Blvd. 

Nashville, TN 37243 

Kingsport Public Library 

400 Broad Street 

Kingsport, TN 37660 

All persons interested in the air quality of the State of Tennessee are urged to attend and will be afforded the opportunity 

to present testimony to the hearing officer regarding the revisions to the proposed Regional Haze State Implementation 

Plan (SIP) to protect visibility in Class I areas. Any person desiring to present lengthy comments should be prepared at 

the hearing to offer a written statement to be incorporated into the record. Written statements not presented at the 

hearings will only be considered part of the records if received by 4:30 p.m. CDT May 7, 2012, at the office of the 

Technical Secretary, Tennessee Air Pollution Control Board, 9th Floor L & C Annex, 401 Church Street, Nashville, 

Tennessee, 37243- 153 1. 

Alternative BART Determination Appendix L.13-17 

Eastman Chemical Company-TN Operations 

Regional Haze SIP for TN Class I Areas 

April 4, 2012 

yy qppgyy Qy 

Styke at (615) 532-0562. Copies of documents concerning these matters are available for review at the 

office of the Technical Secretary and at certain public depositories. For information about reviewing these 

documents, please contact Mr. Malcolm Butler, 9Ih Floor, L & C Annex, 401 Church Street, Nashville, TN 

37243-1 53 1, telephone (6 15) 532-0600. 

Summary of Proposed Change 

Regional haze is fine particle pollution that impairs visibility over a large region including Class I areas 

such as national parks and wilderness areas. Sources of haze-forming emissions include coal-fired power 

plants, industrial boilers, and mobile source emissions. U. S. EPA's regional haze rule requires states to 

demonstrate reasonable progress toward meeting the national goal of a return to natural visibility conditions 

by 2064. The rule directs states to show a uniform rate of progress toward natural conditions for each Class 

I area in Tennessee and for certain areas in other states. 

Regional Haze State Implementation Plans (SIPS) must include an assessment of baseline visibility 

conditions and a monitoring strategy for measuring, characterizing, and reporting of regional haze visibility 

impairment. States must also consider ongoing control programs, measures to mitigate construction 

activities, source retirement and replacement schedules, smoke management programs for agriculture and 

forestry, and enforceability of specific measures. 

This will be the third public hearing for Tennessee's Regional Haze SIP, and this hearing is limited to the 

proposed changes to the Best Available Retrofit Technology (BART) requirements for Powerhouse B-253 

at Eastman Chemical Company in Kingsport, Tennessee. The proposed revisions provide Eastman 

Chemical Company the option to repower this powerhouse from coal to natural gas if it is determined to be 

necessary to comply with other federal requirements. At both Class I areas in Tennessee, visibility 

improvements on the worst days are expected to be better than the uniform rate of progress glide path by 

201 8 based solely on reductions from existing and planned emissions controls. 
Air Pollution Control Division 

Nashville EFO 

7 1 1 R. S. Gass Blvd. 

Nashville, TN 37243 

Kingsport Public Library 

400 Broad Street 

Kingsport, TN 37660 

All persons interested in the air quality of the State of Tennessee are urged to attend and will be afforded the 

opportunity to present testimony to the hearing officer regarding the revisions to the proposed Regional Haze 

State Implementation Plan (SIP) to protect visibility in Class I areas. Any person desiring to present lengthy 

comments should be prepared at the hearing to offer a written statement to be incorporated into the record. 

Written statements not presented at the hearings will only be considered part of the records if received by 4:30 

p.m. CDT May 7, 2012, at the office of the Technical Secretary, Tennessee Air Pollution Control Board, 9th 

Floor L & C Annex, 401 Church Street, Nashville, Tennessee, 37243-1531. 

g y y 

Tennessee Air Pollution Control Board. The source specific SIP revision will be 

part of Tennessee's Regional Haze SIP and apply to the 8-253 Powerhouse at 

Eastman Chemical Company in Kingsport, Tennessee. 

Notice of the public hearing appeared on the Tennessee Department of 

Environment and Conservation's web site with a 30 day period for public 

inspection of the documents applicable to today's public hearing. The notice and 

the materials in the public depository are being made a part of the hearing 

record. 
visibility impairing pollutants were required to implement Best Available Retrofit 

Technology or BART to control the pollutants. /The federal statutes and 

regulations require that BART be implemented as expeditiously as practicable, but 

no later than 5 years after it has been required. An option known as Alternative 

BART is possible as long as the reductions in visibility impairing pollutants are 

greater than BART and that they occur within the first 10 year planning period. 

The state of Tennessee submitted its regional haze SIP to EPA in April of 2008 with 

a source specific permit for the B-253 Powerhouse at Eastman Chemical Company 

that would activate upon EPA's approval of the Tennessee Regional Haze SIP. 
suggests that BART as originally envisioned may not be enough to attain the 

ambient sulfur dioxide standard. 

Eastman Chemical Company is evaluating the possibility of re-powering the 8-253 

Powerhouse to natural gas and may also repower other boilers as needed to 

natural gas to be able to predict attainment of the ambient sulfur dioxide 

standard. Repowering to natural gas will result in even greater emission 

reductions of visibility impairing sulfur oxides than BART alone and essentially 

eliminate them altogether. For that reason, the state of Tennessee is proposing 
powering the B-253 Powerhouse to natural gas no later than July 31,2018. 

Comments have been received that aver the alternative BART deadline to 

repower should be extended to December 31,2018. Comments are expected 

from EPA as part of this hearing, and the state of Tennessee declares that if the 

EPA is agreeable to extending the deadline to re-power to December 31,2018, it 

will be so extended in the final proposed source specific SIP revision permit for 

EPAJs review and approval into the federally approved version of the Tennessee 

Regional Haze State Implementation Plan. 
to the proposed permit or its accompanying narrative will be made. The 

proposed final documents will be presented to the Tennessee Air Pollution 

Control Board on May 9,2012 at its regularly scheduled meeting. Upon approval 

by the Board, the order to retract the previously submitted BART permit for 

Eastman and its replacement by a new permit that establishes a new BART and a 

new Alternative BART path will be promptly submitted to EPA for approval and 

inclusion into the Tennessee Regional Haze SIP. 

I will now open the hearing to any oral comments. 

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Eastman Chemical Company 

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pursuant to 40 CFR 51.308(e)(2). According to these regulations, such alternative measure must achieve 

greater reasonable progress than would be achieved through the installation and operation of BART. 

Eastman agrees with TDEC's conclusion in the SIP revision that the alternative measure clearly results in 

greater reductions in the visibility impairing pollutant (sulfur dioxide) than BART, since BART would have 

reduced the sulfur dioxide emission rate to 0.2 pounds per million Btu of heat input and the alternative 

measure would reduce the emission rate to essentially zero. 

The other important criteria for approval of an alternative measure is that all the reductions take place 

during the period of the first long-term strategy for regional haze (see 40 CFR 5lV308(e)(2)(iii)). TDEC's 

proposed permit condition defines deadline for completion of the alternative measure as July 31,2018 

and states in the narrative that this'date is "within the period of the first long-term strategy." Eastman 

objects to this deadline as arbitrary and unnecessarily shortening the allowable time for Eastman to 

complete the project, which clearly provides significantly greater progress in reduction of visibility 

impairment in Class I Areas. 

Eastman finds no basis for this deadline in either guidance, the regional haze regulations or preambles, 

or the Tennessee Regional Haze SIP. All references we can locate refer to the first planning period as 

including the year 2018. References we have located are as follows: 

Regional Haze Regulations, Final Rule, 64 Federal Register 35732, July 1, 1999: 

"Hence, in identifying the amount of progress needed between the baseline and the end 

of the implementation period (i.e., the year 2018) ..." 

b4 OUR ClspoNsIBIE COMMITMENT TO SUSTAINABILITY C*P1-@ 
In addition to the plain language above indicating EPA intended the first planning period to end on 

December 31,2018, there are additional justifications for granting Eastman the maximum time allowed 

under the rule. First and foremost, the potential change from coal to natural gas at Building 253 

powerhouse represents a fundamental strategic change for Eastman with far-reaching implications. 

Eastman began using coal as a source of energy at the Kingsport site in custom-designed boilers in 1929, , 

and has reinvested in its coal-based energy infrastructure ever since. Migrating approximately half the 

Kingsport site's energy portfolio from coal to natural gas after over 80 years of reliable and costeffective service represents a major strategic change for Eastman. Such far-reaching decisions can only 

be made by Eastman's Board of Directors, and the fiduciary responsibility of the Board requires that any 

such decision undergo considerable scrutiny and analysis. This level of scrutiny requires time, and the 

interests of making a good decision argues for the maximum flexibility allowed under the regulations. 

Second, the technical complexity of converting coal boilers to fire natural gas cannot be overstated. The 

five boilers at Building 253 were custom engineered to burn a specific grade of bituminous coal. The 

original designers have been engaged to evaluate whether it is technically feasible to convert the boilers 

to fire natural gas, but none of the detailed engineering required for such a modification has been 

performed. This means that Eastman has a basis for believing that the boilers can be converted to fire 

natural gas, but has very little visibility about the extent of technical modifications required to effect 

such a conversion. Changes to how heat is distributed throughout the boilers, circulation patterns, load 

response, and basic unit performance are all unquantified. Physical changes to boiler metallurgy, 

attemperating water systems, and to remain current with NFPA fire codes are all unquantified. And the 

commissioning, checkout and requirements for tuning of the combustion control systems and the flame 

safety and stability systems are unquantified. None of these hurdles appear to be insurmountable, but 

the considerable technical risks can only be addressed through detailed engineering up front, and a 

disciplined checkout and commissioning process after the first unit is converted. Addressing these 

Eastman Comment 

Page 2 of 3 
y, p

that the FERC and pipeline owner's processes are outside Eastman's control, only Eastman stands to be 

held accountable if it takes longer to deliver the required volume of natural gas to the Kingsport site 

than Eastman currently assumes. Mitigating this business risk by setting a December 31, 2018, deadline 

is both reasonable and within the state of Tennessee's authority. 

Lastly, one additional minor comment is that Eastman requests the SIP revision narrative clarify in Table 

1 that the emission rate shown for alternative BART (0.0006 Ib/MMBtu) is not to be construed to 

represent an enforceable emission limit. The amount of sulfur present in natural gas is insignificant, but 

it is not controlled by the producers of the gas nor by the pipeline companies that transport the gas. 

The figure cited above is simply the emission rate shown for natural gas boilers in EPA's Emission Factor 

document (AP-42 sth Edition, Table 1.4-2). This value was given by Eastman to simply illustrate that 

sulfur dioxide emissions from natural gas combustion will be far lower than from post-combustion SO2 

controls on coal-fired boilers, and should not be used as the basis for establishing a numerical limit. 

If you have any questions concerning these comments, please contact me at (423)229-2327. 

step hen'^. ~osskt, P.E. 

Environmental Fellow < 

1 AEP Shares Plan For Compliance With Proposed EPA Regulations, June 9,2011, 

http://www.aep.com/newsroom/newsreleases/?id=1697 

Eastman Comment 

Page 3 of 3 



y p; Qy y

Cc: Davis.ScottR@e~amaiI.epa.~ov; Notarianni.Michele@e~amail.e~a .aov; Calcacmi.John@e~amail.epa.aov; Sean 

Lakeman 

Subject: Comments from the Litigants on Proposed Tennessee Regional Haze SIP 

Hello Barry and Quincy, 

Please see message below from NCPA on the proposed TN Regional Haze SIP .... May 15,2012 is approaching quickly 

and we will need to have resolution no later than around May 1,2012 to get the extension process. We can discuss more 

this week. We wanted to get these to you as quickly as we got them so that you can review and see what you will likely 

get in the way of comments on your proposal. I 

I hope your day is going well. 

Lynorae Benjamin, Chief 

Regulatory Development.Section 

U.S. Environmental Protection Agency, Region 4 

61 Forsyth Street, S.W. 

Atlanta, Georgia 30303 

phone: 404-562-9040 

facsimile: 404-562-901 9 

David Baron wrote the following ... 

The state copied us on the attached drafts of the SIP revision for the Eastman plant in Tennessee. We have the following concerns 

with this proposal: 

1. The SIP narrative (p.9) indicates that, under the option of repowering to gas, the 4 boilers at issue will be converted to 

gas in sequence by different dates in 2016, 2017 and 2018. However, the draft permit sets only an outside deadline for 

completing conversion of all 4. The permit should have separate deadlines for completion of each boiler conversion 

corresponding to the time frames shown in Table 2 of the SIP revision. Sequential deadlines are particularly important given 

that the final deadline (July 2018) is more than a year past the original BART deadline of April 2017. 

2. The draft permit is written in confusing fashion that does not set out Eastman's obligations with sufficient clarity. 

Condition '3'says that Eastman must comply with Conditions 1 and 2 except as otherwise allowed by Condition 4 (The draft 

Managing Attorney 

Earthjustice 

1 625 Massachusetts Avenue, NW, Suite 702 

Washington, DC 20036 

(202) 667-4500 Ext. 5203 (phone) 

(202) 667-2356 (fax) 

dbaron 8earthiustice.ora <mailto:dbaron @earthiustice.ora> 


deadline for filing written comments on this BART alternative proposal is May 7,20 12. 

The EPA acknowledges and appreciates the State's efforts in promoting and developing approaches that 

seek to achieve greater reasonable progress toward the national visibility goal than would be achieved 

through the installation and operation of BART. The EPA expects to act promptly on this SIP 

amendment once it is finalized and formally submitted to the Agency. 

The EPA will reach a final conclusion regarding the adequacy of the State's amended regional haze SIP 

once the Agency reviews the final submission and completes our public notice and comment rulemaking 

process. We look forward to continued collaboration with you and your staff to improve visibility in the 

nation's Class I national parks and wilderness areas. Please do not hesitate to contact me or Beverly 

Banister at (404) 562-9070 if you have any questions. 

A. Stanley Meiburg 

Deputy Regional Administrator 

cc: Barry R. Stephens, TDEC 

Let me know if you have questions. If you prefer a more formal letter in response to your 

request for review, we can do that; just let me know. 

Good talking to you, 

Pat Brewer 

Pat Brewer 

National Park Service 

Air Resource Division 

303-969-2153 

Lacey Hardin 

<Lacey . Hardinetn. 

gov> 

"'baanderson02~s.fed.u~'" 

tbaanderson02@fs.fed.u~>, 

"'Patricia~F~Brewer@nps.govl" 

<Patricia F Brewer@nps.gov>, 

"'Tim~Allen@Fws.gov'" 

<Tim Allen@fws.~ov>, 

"'Don-Shepherd@nps.govl" 

<Don Shepherd@nps.gov> 

CC 

"Benjamin.Lynorae@epamail.epa.Rov" 

<Benjamin.Lynorae@epamail.epa.aov>, 

Haidar Alrawi 

The National Park Service (NPS) has reviewed the Tennessee Department of Environment and 

Conservation (TDEC)'s proposed alternative for Best Available Retrofit Technology (BART) for 

Eastman Chemical Company and supports TDEC's condusion that the alternative BART 

measure would result in greater progress in improving visibility at Great Smoky Mountains 

National Park. 

In 2008, TDEC determined that a sulfur dioxide emissions limit of 0.2 IbImmBtu is BART for 

the five coal-fired boilers at Eastman's B-253 Powerhouse, TDEC now proposes to retain this 

emissions limit if Eastrnan continues to bum coal and to modify the permit to allow Eastman a 

BART alternative to repower the coal-fired boilers with natural gas with an effective sulfur 

dioxide emissions rate of 0.0006 Ib/mrnBtu. Because natural gas has little sulfiu content, the 

alternative would accomplish greater reductions in sulhr dioxide emissions than the original 

BART determination. Due to uncertainty in siting and sizing a natural gas pipeline, TDEC is 

proposing to allow an additional year, to July 31,2018, if Eastrnan chooses to implement the 

BART alternative. 

Every year after 201 8, sulhr dioxide emissions will be lower under the BART alternative than 

under the original BART. Eastman Chemical Company was one of the first industrial sources 

nationally to agree to emissions reductions for BART. We commend Eastman's willingness to 

act in 2008 and we support TDEC's proposed BART alternative for Eastman now. 

We appreciate the opportunity to work closely with TDEC and the U,S. Environmental 

Protection Agency to make progress toward achieving natural visibility conditions at our 

National Parks and Wilderness Areas. 


CONDITIONS: 

1. In accordance with the requirements of 40 CFR 5 1.308 (BART), the following emission limitation is established: 

Sulfur dioxide (SOz) emissions from Boilers 25-29 shall comply with the less stringent of the following limits: 

0.20 pounds of SO2 per million British Thermal Units (IblMMBtu) of heat input; or 

Reduce uncontrolled SO2 emissions by '92%. 

Compliance with these emission limits shall be determined on a thirty (30) calendar day rolling average basis as the average 

emission rate, or average SO2 reduction, from either each boiler individually while combusting coal, or averaged across all of 

the boilers that are combusting coal. 

(conditions continued on next page) 

No Authority is Granted by this Permit to Operate, Construct, 

Law, Statute, Code, Ordinance, Rule, or Regulation .of the State of Tennessee or any of its Political 

Subdivisions. 

NON-TRANSMLE 

CN-0827 (Rev. 9-92) 

POST AT INSTALLATION ADDRESS 

RDA- 1298 
Monitoring Plan: Monitoring shall be conducted as specified in an approved sitespecific monitoring plan. The monitoring plan 

must be submitted to the Technical Secretary at least ninety (90) days prior to the startup of the control device. 

Recordkming All records required to demonstrate compliance with this condition shall be maintained at the source location 

and kept available for inspection by the Technical Secretary or his representative. Records shall be maintained for five (5) years. 

3. Compliance Schedule: Except as otherwise allowed by Condition 4 of this permit, Eastman Chemical Company shall 

comply with Conditions 1 and 2 of this permit no later than April 30,2017. 

4. Alternative BART Requirements: In lieu of complying with BART as specified in Conditions 1,2, and 3 of this permit, 

the permittee may choose to implement Alternative BART, as follows: 

(a) The permittee shall submit written quarterly progress reports to the Technical Secretary and to the U. S. 

Environmental Protection Agency (EPA), Region 4 Office. The initial report shall be submitted no later than July 1, 

2012. Subsequent reports shall be submitted within one calendar quarter of the previous report. 

(i) The reports shall summarize the permittee's acquisition of site-specific meteorological data at the 

permittee's Kingsport Meadowview site and the modeling results obtained from the data. Only the 

modeling analyses that are used to determine whether the BART requirements specified in Conditions 1 

and 2 of this permit will be sufficient to attain and maintain the one hour sulfur dioxide NAAQS need be 

addressed in the submittals. If the permittee concludes that compliance with Conditions 1 and 2 of this 

permit are not sufficient to demonstrate attainment and maintenance of the one hour sulfur dioxide 

NAAQS, the permittee shall include summaries of modeling results showing the predicted ambient impacts 

of repowering the B-253 Powerhouse to natural gas (and other boilers at the facility, if needed to comply 

with the one hour sulfur dioxide NAAQS) with the quarterly progress reports. 

(ii) If the permittee determines to repower its boilers at its Kingsport, Tennessee facility, the quarterly written 

report submitted according to the schedule in Condition 4(a) shall contact the natural gas supplier for the, 

area and summarize what the permittee knows regarding the progress on the project to modify the thirdparty natural gas pipeline to provide sufficient natural gas to the permittee's facility. 
This permit shall remain valid until Title V Operating Permit 557888 is reopened to include the requirements of this permit. 

(end of conditions) 

qy

qqp()() 

place during the period of the first long-term strategy for regional haze. 

Upon recommendatiqn by the staff for approval, the Board finds that the Alternative BART Determination for Easm 

Chemical Comp~y - Temessee Operatiom includes a compliance option that meets the requirements of $51.308(e)(l) for 

BART and an option that meets the requirements of #51.308(e)(2) for alternative measures. The Board approves the 

withdrawal of operating peanit 061873H (BART permit for Eastman Chemical Company issued March 3 1,2008). The Board 

approves the submittal of the AItelllatrmve BART Determination for Eastman Chemical Company - Tennessee Operations and 

operating permit 0661 16H (BART pdt for Eastman Chemical Company issued May 9,2012) to U. S. EPA for adoption into 

Tennessee's State Implementation Plan. 

Approved on May 9,2012, by the members of the Tennessee Air Pollution Control Boa