May 14,2012 STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION I DIVISION OF AIR POLLUTION CONTROL gTnFLOOR L & C ANNEX

401 CHURCH STREET NASHVILLE. TENNESSEE 37243-1531

A. Stanley Meiburg Regional Administrator US EPA, Region IV Atlanta Federal Center, I 

### 2"' Floor 6 1 Forsyth Street, SW Atlanta, GA 30303-3 104

RE: Tennessee Regional Haze State Implementation Plan

Dear Mr. Meiburg:

On May 9. 2012. the Tenr~essee Air Pollution Control Board adopted Board Order 12-008. The Board Order approves the withdrawal of operating permit 061873H (BART pemut for Eastrnan Chemical Company issued March 31. 3008). The Order also approves the submittal of the Alternative 

### BART Dctcrminiz/iorl./or EUJINIUII Chemical Company - Tennessee Operations and operating permit 0661 16H (BART penmt for Eastman Chemical 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

### SIP Submittal Documents List of Attachments 

# I Attachment 

## 1 Descri~tion 

# 1

- -- Regional Haze Alternative BART Determination 

### - Eastman Chemical Company

Attachment 5 

# 1 Board Order 12-008 Attachment 2 Attachment 3

Attachment 4 Public Notice Information Public Comment Summary (Hearing Officer Statement and Public Comments from Eastman Chemical Company, Earth Justice, National Park Service, and EPA) BART Permit 066 1 16H

# Regional Haze State Implementation Plan
for
Tennessee Class I Areas

Alternative BART Determination Eastman Chemical Company 

# -Tennessee Operations

Prepared by 

## Tennessee Department of Environment and Conservation
Division of Air PollutionControl

April 4,2012

# Attachment 1
Regional Haze Alternative BART Determination 

# - Eastman Chemical Company

# Appendix L-13 Alternative BART Determination Eastman Chemical Company 

# - Tennessee Operations

--- - - Alternative BART Determination Eastman Chemlcal Company-TN Operations Regional Haze SIP for TN Class I Areas Appendix L.13-2 April 4, 2012

### EastmaaChemical Altermve 

### BART Determination:

Pursuant to40 CFR 51.308(e)(2), the state of Tennessee is establishing an alternate emission reduction measure for its best available retrofit technology (BART) determination at the Eastman 

### Chemical Company's (Eastman) B-253 

### Powerhouse in Kingsport, Tennessee. A new permit condition will 

### be added tothe existing permit 

### No. 061873H (See Attachment 1, 

### page 12, Condition 

### 4) that establishes this new Tennessee State 

### Implementation Plan (SIP) applicable requirement.

In accordance with Rule 1200-03-9-.02(11)(f)5.(i), 

### only the portion of the current permit that pertains tothe addition to this new SIP applicable requirement is being reopened. Generally, the state ofTennessee must prove to EPA's satisfaction that the alternative BART measures at Eastman's 8-253 Powerhouse will result in a greater reasonable progress than would have resulted from the installation and operation of the post combustion controls when burning coal
as described in Conditions 1-3 of Permit No. 061873H (See Attachment 1, 

### pages 12 and 13).

The federal regional haze regulations allow states to set a BART limit or an Alternative BART limit. If Eastman chooses BART it 

### must be implemented by April 30,2017. If Eastman chooses to implement Alternative BART, it 

### must be implemented by July 31, 2018.

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

### TABLE 

### OF 

### CONTENTS



## ............................................................ Eastman Chemical Alternative BART Determination 

### 4

Figure 1- 

### TN BART Eligible Sources Locations



## ......................................................................... 5



### Figure 2- TN BART Eligible Sources and Class 

### I areas


## .............................................................. 5



### Table 1-

### BART vs



# . Alternative BART Sulfur Dioxide Emission Limits



## ..................................... 8



### Table 2- Projected BARTvs



## .Alternative BART SO2 and NOx Emission Reductions



## .......... 9



### ATACHMENT 

### 1 -Eastman Chemical BART Operating Permit



## ............................................ 11



### AlTACHMENT 2 -Eastman Chemical Alternative BART Public Hearing Notice



## ................15

-- Alternative BART DeZermination Appendix L.13.3 Eastman Chemical Company-TN Operations Regional Haze SIP 

### for TN Class 1 Areas April 4. 2012

### Figure 1-TN BART Eligible Sources Locations

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

### FACILITY NAME:

1) 

### Aluminum Company of America (Alcoa) -South Plant
2) DuPont White Pigment and Mineral Products (Humphreys County)


### 3) Eastman Chemical Company 

# - Tennessee Operations
4) E I DuPont de Nemours and Company, Inc. (Old Hickory)
5) E I DuPont de Nemours and Company, Inc. (Shelby County)
6) Holston Army Ammunition Plant


### 7) Inter-trade Holdings, Inc.
8) Liberty Fibers Corporation


### 9) Lucite International
10)Owens Corning
11)

### Packaging Corporation of America (PCA)
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

### facility were either built before August 1962 or were built or modified after the promulgation of major NSR rules in 1977. The power boiler (#7)at the Weyerhaeuser facility (now Domtar Paper Company) in Sullivan County has been retired and the facility is no longer BART eligible. For more detailed permit information on these BART exempted sources, see Appendix L-12. The BART status of the remaining twelve (12) operational sources is as follows:

1) 

### Aluminum Company of America (Alcoa)-South Plant
2) DuPont White Pigment and Mineral Products (Humphreys County)


### 3) Eastman Chemical Company

# - Tennessee Operations
4) 

### E I 

### DuPont de Nemours and Company, Inc. (Old Hickory)


### 5) E 1 

### DuPont de Nemours and Company, Inc. (Shelby County)
6) 

### Lucite International
7) Owens Corning
8) Packaging Corporation of America (PCA)
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 sources1S02emissions and distance to Class 

### I areas is included as Appendix L-3.

TN BART-eligible sources were presumedto 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 pertainsto 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

### action on the Tennessee Regional Haze SIP, it 

### is believed that all applicable requirements of establishing a BART limitation have been met. If EPA approvesthe coal-fired, post combustion control BART demonstration that appears in Condition 1 

### of Permit No. 061873H in the Tennessee Regional Haze SIP, it 

### should satisfy the requirement of Section 302(c) or paragraph (e)(l) of the section, or otherwise addressed under paragraphs (e)(l) or (e)(4)of the section.

40 CFR 

### 5lV308(e)(2)(i)(C) requires an analysis of the best system of continuous emission control technology available and associated emission reductions achievable for each source within Tennessee subject to BART and covered by the alternative program. As mentioned previously, the alternative BART beingestablished in this action is 

### limited to the five boilers at Eastman's 

### B253 Powerhouse with no trading at other BART facilities in Tennessee. TDEC previously determined BART for these units in its April 

### 4, 2008 Regional Haze SIP. There is no change to the determination that a 0.2 Ib S02/MMBtu limit 

### is BART for these units. If Eastman elects to pursue 

### its plan to re-power all five coal-fired boilers at its 

### 8-253 Powerhouse to natural gas firing, Tennessee has made the determination that it 

### will represent the ultimate control of sulfur oxides, and is far superior to reducingthis visibility impairing pollutant compared to coal-fired boilers using post-combustionsulfur oxides control technology. The Tennessee Regional Haze SIP has made the demonstration that sulfur oxides forming sulfates is the principal cause of visibility impairment at the Class 1 

### Areas in the Eastern United States. As natural gas contains essentially no sulfur, it 

### is easily demonstratedthat it is 

### a superior method of controlling sulfur oxide emissions.

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

### Table 2- Projected BART versus Alternative BART SO2 and NOx Emission Reductions

Table 2 represents projected emissions into the future and should not be viewed as actual emission levels and are not legally binding. The actual binding emission levels would be set in a construction permit described under condition 4(b) of proposed permit (See Attachment 1, 

### page 14).

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 notrading 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 twotests
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

### Tennessee submits that Table 2 above conclusively demonstrates that emission reductions using alternative BART are greater over time than BART.

40 CFR 

### 51.308(e)(2)(iii)requires that all necessary emission reduction take place during the period of the first long-term strategy for regional haze. An examination of the permit condition establishing alternative BART reveals that the maximum amount of time allowed to repower the five boilers at Eastman's 8-253 Powerhouse is 

### set at July 31, 2018, thereby occurringwithin the period of the first long-term strategy. The alternative BART permit condition also details the procedures for accounting and monitoring the emissions. Previously approved into the Tennessee SIP 

### is Division Rule 1200-03-9-.02(6)which requires all permittees to comply with the conditions of their operating permit. Violation of the permit condition is by definition, violation of Rule 1200-03-9-.02(6)and grounds for enforcement action.

40 CFR 

### 51.308(e)(Z)(iv) requires a demonstration that emission reductions from trading or other alternative measures are surplus. As mentioned previously, this alternative BART permit condition is not part of a trading program and as such, a demonstration of surplus emission for purposes of trading 

### is not required. The alternative BART at Eastman's 8-253 Powerhousewill result in surplus emission reductions in that the additional emission reductions beyond traditional BART shown in Table 

### 1 above are not required under the federal Clean Air Act as of the baseline date of the Tennessee Regional Haze SIP.

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 reductionsof 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

# Attachment-1 Eastman Chemical Company BART Operating Permit

Alternative BART Determination Appendix L.13-11 Eastman Chemical Company-TN Operations April 4, 2012 Regional Haze SIP for TN Class I AreasTENNESSEE AIR POLLUTION CONTROL BOARD DEPARTMENT OF ENVIRONMENT AND CONSERVATION 

### NASHVILLE, TENNESSEE 37243- 153 1

OPERATING PERMIT Issued Pursuant to Tennessee Air Quality Act Date Issued: March 3 1,2008 Permit Number:

Date 

### Amended:

Date Expires: July 31,2018 [AMENDMENT]

Issued To:

Eastman Chemical Company Tennessee Operations Installation Address:

South Eastman Road Kingsport

Installation Description:

Powerhouse B-253- I, Boilers #25-#29 Emission Source Reference No.

82-0003-00 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 SO2per million British Thermal Units (Ib!MMBtu) of heat input; or

Reduce uncontrolled SO2emissions 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~it o 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, 2012Monitoring Requirements:

Measurement of SO? emissions: SO2 emissions shall be measured through the use of continuous in-stack monitoring for sulfurdioxide, as specified below:

The source owner or operator shall install, maintain, operate, and submit quarterly reports of excess emissions and sulfur dioxide (SO2) removal efficiency (if applicable) from continuous in-stack monitoring systems for sulfur dioxide (SO,). The sulfur dioxide monitoring systems shall meet all the requirements of 40 CFR 60 Appendices A and B, or40 CFR Part 75 Appendices A and F.
Compliance will be determined on a 30 calendar day rolling average basis. Each 30 calendar day average shall be the average of the valid daily averages during the previous thuty (30) calendar days

O~erational reauirements for Sulfur Dioxide (SO?) Monitoring Systems: For this fuel burning installation to demonstrate continual compliance with the B&T sulfur dioxide emission limitation, each sulfur dioxide monitoring system for boilers #25-#29 shall be fully operational for at least ninety five percent (95%) of the operational time (during which coal is combusted) of the monitored units during each calendar quarter. Operational availability levels of less than these amounts may be considered the basis for declaring the fuel burning installation in noncompliance with the applicable monitoring requirements, unless the reasons for the failure to maintain these levels of operational availability are accepted by the Technical Secretary as being legitimate malfunctions of the instruments. Data recorded during periods of monitoring system breakdown, repairs, calibration checks, and zero and span adjustments shall not be included in the data averages.
Ouality Assurance requirements for the Sulfur Dioxide (SO?) 

### - Monitoring Systems: The continuous in-stack sulfur dioxide monitoring systems shall meet all of the requirements of 40 CFR Part 60 Appendix B (Performance Specification 2) and 40 CFR Part 60 Appendix F; or 40 CFR Part 75 Appendices A and B.

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 1and 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, 2012boilers 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 re-power 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 third-party natural gas pipeline to provide sufficient natural gas to the permittee's facility.

The permittee shall submit applications for any construction permit(s) as needed to establish emission limits and other applicable requirements to repower the boilers.

If the permittee determines that Alternative BART is not feasible for this facility, the permittee shall provide written notification to the Technical Secretary and the EPA Region 4 Office in a final quarterly report. Upon submittal of this notification, the permittee shall comply with Conditions 1 and 2 of this permit no later than April 30,2017.

The permittee is placed on notice that the issuance of this permit does not excuse it from any other applicable air pollution control requirements that may become applicable as a result of repowering to natural gas.

If the permittee elects to repower its B-253 Powerhouse boilers to natural gas, the conversion shall be accomplished no later than the earlier of:

(i) The compliance deadline for the one-hour sulfur dioxide NAAQS established in an approved State Implantation Plan revision, or
(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

# Attachment-2 Eastman Chemical Company Alternative BART Public Hearing Notice

Alternative BART Determination Appendix L.13-15 Eastman Chemical Company-TN Operations Regional Haze SIP for TN Class I Areas April 4, 2012NOTICE OF PUBLIC HEARING TENNESSEE DEPARTMENT 

### OF ENVIRONMENT AND CONSERVATION DIVISION 

### OF AIR POLLUTION CONTROL

There will be a public hearing before the Technical Secretary of the Tennessee Air Pollutio~i Control Board to consider amendments to the proposed Regional Haze SIP to protect visibility in Class I areas pursuant to Tennessee Code Annotated, Section 68-201-105. The comments received at this hearing will be presented to the Tennessee Air Pollution Control Board for their consideration. The hearing will be conducted in the
manner prescribed by the Uniform Administrative Procedures Act, Tennessee Code Annotated, Section 4-5- 201 et. seq. and will take place in the 9th Floor Conference Room of the L & C Annex, located at 401 Church Street, Nashville, Tennessee 37243-1531 at 10:OO a.m. on May 7,2012.

Written comments will be included in the hearing records if received by the close of business (4:30 PM CDT) May 7, 2012, at the office of the Technical Secretary, Tennessee Air Pollution Control Board, 9th Floor, L & C Annex, 40 1 Church Street, Nashville, TN 37243-153 1.
Any individuals with disabilities who wish to participate in these proceedings (or to review these filings) should contact the Tennessee Department of Environment and Conservation to discuss any auxiliary aids or services needed to facilitate such participation. Such initial contact may be in person, by writing, telephone, or other means, and should be made no less than ten (10) days prior to May 7,20 12, or the date such party intends to review such filings, to allow time to provide such aid or service. Contact the Tennessee Department of Environment and Conservation ADA Coordinator, 121hFloor, 401 Church Street, Nashville TN 37243; (615) 532-0207. Hearing impaired callers may use the Tennessee Relay Service (1-800-848-0298).



### If you have any questions about the proposed Regional Haze SIP documents you may contact Mr. Quincy 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, 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 areexpected 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, 2012Revisions considered at this hearing may be adopted by the Tennessee Air Pollution Control Board under T.C.A. 68- 201-105, the Board general authority to promulgate rules.
Materials concerning the proposed additions and/or revisions will be available for public inspection during normal working hours starting April 5,2012, at the following locations and on this website:

Air Pollution Control Division 9th Floor, L & C Annex 401 Church Street Nashville, TN 37243



### Air Pollution Control Division Knoxville EFO 37 

### 1 1 Middlebrook Pk Knoxville, TN 37921

Air Pollution Control Division Columbia EFO 142 1 Hampshrre Pike Columbia, TN 3840 1

Air Pollution Control Division Chattanooga 

### EFO Suite 550 540 McCallie Ave. Chattanooga, TN 37402 

### - 20 13

Air Pollution Control Division Nashville EFO 71 1 R. 

### S. Gass Blvd. 

### Nashville,TN 37243 Chattanooga 

## - Hamilton County Air Pollution Control Bureau 6 125 Preservation Drive Chattanooga, TN 374 16

Air Pollution Control Division Johnson City EFO 2305 Silverdale Road Johnson City, TN 3760 1 

## - 2 162

Knox County Department of Air Pollution Control 140 Dameron Avenue Knoxville, TN 379 17-64 13

Pollution Control Division Metropolitan Health Department 3 1 1 23rd Ave. North Nashville, TN 37203

Kingsport Public Library 400 Broad Street Kingsport, TN 37660 Air Pollution Control Division Cookeville EFO 1221 South Willow Ave. Cookeville, TN 38506

Air Pollution Control Division Jackson EFO 1625 Hollywood Drive Jackson, TN 38305

Division Air Pollution Control Memphis 

### - Shelby Co. Health Dept. 8 14 Jefferson Avenue Memphis, TN 38 105

U.S. EPA, Region IV APTMD 

### - 12th Floor Atlanta Federal Center 6 1 Forsyth Street S.W. Atlanta, Georgia 30303 C/O Mr. Scott R. Davis, Chief

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.

Alternative BART Determination Appendix L.13-17 Eastman Chemical Company-TN Operations Regional Haze SIP for TN Class I Areas April 4, 2012

# Attachment 2


# Public Notice InformationPage 1 of 

### 2 pages

NOTICE OF PUBLIC HEAFUNG TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION DIVISION OF AIR POLLUTION CONTROL

There will be a public hearing before the Technical Secretary of the Tennessee Air Pollution Control Board to consider amendments to the proposed Regional Haze SIP to protect visibility in Class I areas pursuant to Tennessee Code Annotated, Section 68-201-105. The comments received at this hearing will be presented to the Tennessee Air Pollution Control Board for their consideration. The hearing will be conducted in the manner prescribed by the Uniform Administrative Procedures Act, Tennessee Code Annotated, Section 4- 5-201 et. seq. and will take place in the 9th Floor Conference Room of the L & C Annex, located at 401 Church Street, Nashville, Tennessee 37243-153 1 at 10:OO a.m. on May 7,2012.

Written comments will be included in the hearing records if received by the close of business (4:30 PM 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, TN 37243-153 1.
Any individuals with disabilities who wish to participate in these proceedings (or to review these filings) should contact the Tennessee Department of Environment and Conservation to discuss any auxiliary aids or services needed to facilitate such participation. Such initial contact may be in person, by writing, telephone,

or other means, and should be made no less than ten (10) days prior to May 7,2012, or the date such party intends to review such filings, to allow time to provide such aid or service. Contact the Tennessee Department of Environment and Conservation ADA Coordinator, 12'" Floor, 401 Church Street, Nashville TN 37243, (615) 532-0207. Hearing impaired callers may use the Tennessee Relay Service (1-800-848- 0298).

If you have any questions about the proposed Regional Haze SIP documents you may contact Mr. Quincy 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 37243-1 531, 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.Page 2 of 

### 2 pages

Revisions considered at this hearing may be adopted by the Tennessee Air Pollution Control Board under T.C.A. 68-20 1- 105, the Board general authority to promulgate rules.
Materials concerning the proposed additions and/or revisions will be available for public inspection during normal working hours starting April 5,2012, at the following locations and on this website:

Air Pollution Control Division 9th Floor, L & C Annex 401 Church Street Nashville, TN 37243

Air Pollution Control Division Knoxville EFO 37 1 1 Middlebrook Pk Knoxville, TN 37921

Air Pollution Control Division Columbia EFO 142 1 Hampshire Pike Columbia, TN 3840 1

Air Pollution Control Division Chattanooga EFO Suite 550 540 McCallie Ave. Chattanooga, TN 37402 

### - 20 13

Air Pollution Control Division Nashville EFO 7 1 1 R. S. Gass Blvd. Nashville, TN 37243 Chattanooga 

### - Hamilton County 

### Air Pollution Control Bureau 6 125 Preservation Drive Chattanooga, TN 374 16

Air Pollution Control Division Johnson City EFO 2305 Silverdale Road Johnson City, TN 37601 

### - 2162
Knox County Department of Air Pollution Control 140 Darneron Avenue Knoxville, TN 379 17-64 13

Pollution Control Division Metropolitan Health Department 3 11 23rd Ave. North Nashville, TN 37203

Kingsport Public Library 400 Broad Street Kingsport, TN 37660 Air Pollution Control Division Cookeville EFO 122 1 South Willow Ave. Cookeville, TN 38506

Air Pollution Control Division Jackson EFO 1625 Hollywood Drive Jackson, TN 38305

DivisionAir Pollution Control Memphis 

### - Shelby Co. Health Dept. 8 14 Jefferson Avenue Memphis, TN 38 105
U.S. EPA, Region IV APTMD 

## - 12th Floor Atlanta Federal Center 61 Forsyth Street S.W. Atlanta, Georgia 30303 c/o Mr. Scott R. Davis, Chief

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.

# Attachment 

# 3
Public Comment Summary

(Hearing Officer Statement and Public Comments from Eastman Chemical Company, Earth Justice, National Park Service, and EPA)

### Hearing Officer Statement

May 7,2012

Good Morning. I 

### am Quincy Styke Ill, Deputy Director of the Tennessee Air

Pollution Control Division. Today is 

### Monday, May 

### 7, 2012 and the time is 

### 10:OO

AM Central. We are in the Tennessee Air Pollution Control Division's Central

Office located in the gth

### Floor of the L&C Annex at 401 Church Street, Nashville,

Tennessee 37243-1531. 1 

## call this public hearing to order in the matter of a 

### source
specific SIP revision to the Tennessee State Implementation Plan. This hearing 

### is

being held under the authority of the Tennessee Air Quality Act and the

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.

### The proceedings of this hearing are being recorded and copies of the hearing

record will be available for the cost of reproduction. Requests for such copies

should be sent to the Technical Secretary at his office. Compilers of the testimony

presented at 

### this hearing reserve the right to include extensive or bulky testimony

by reference only.

States were required to enact state implementation plans to protect and improve

visibility in Class I Areas such 

### as the Great Smoky Mountains National Park with

the goal of restoring the visibility levels to natural conditions by 2064. To get a
good start in reducing haze producing pollutants, certain existing major sources of

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.

### That permit required the installation of post combustion sulfur oxides air

pollution control equipment within five years. EPA has not yet acted upon the

proposed BART permit for Powerhouse 253, and as such, the timeline to install

those controls has not yet been started.

Since the time that the Tennessee Regional Haze SIP 

### has been submitted, EPA has

established a very stringent sulfur dioxide one-hour national ambient air quality

standard. Ambient air monitoring in the vicinity of the Eastman Chemical

Company confirms that this standard 

### is not being attained, and a designation of

nonattainment for the area 

### is expected shortly. Preliminary modeling also

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

Powerhouseto 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. Repoweringto 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

### to establish an alternative BART path at

### the 8-253 Powerhouse of Eastman that

provides for re-powering to natural gas.

The current proposed BART permit sent to EPA for inclusion into the Tennessee

Regional Haze SIP for the 8-253 Powerhouse will be withdrawn for approval by

EPA into the Regional Haze SIP for Tennessee and replaced with a new permit that

establishes two pathways for Eastman to reduce its 

### visibility impairing pollutants

from the Powerhouse. The proposed permit establishes a 

### pathway for BART

using the previously submitted post combustion controls that must be completed

no later than April 30,2017 and an alternative BART pathway that requires repowering 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

EPAJsreview and approval into the federally approved version of the Tennessee

Regional Haze State Implementation Plan.

### Tennessee has also received input from Earth Justice, an environmental advocacy

group that the proposed permit have a 

### date that requires Eastman to declare

early on in the process which path it 

### will pursue. Tennessee will modify the

permit to address this concern with new language.

In just a 

### moment, we will begin receiving oral comments and the hearing will be

held open as long as is needed for all to comment. I will later recess the oral

comment portion of the public hearing and allow the submission of written

comments until the close of business at 

### 4:30 PM Central Time today. At that

time, the hearing will close. Comments received will be summarized and changes

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.

### (Oral comments received, if any


# ... If there are very few, if any that want to make

oral comments, recess until 10:30 AM and go back on the record.)

All Right. I 

### reconvene the hearing to close the oral comment period and declare

that the written comment period will continue until 4:30 PM 

### Central time today,

May 7,2012.

Thank You.PublicHearingCommentSummaryBART&AlternativeBARTSource SpecificSIPRevisionPermitFor InclusionIntoTheTennesseeRegionalHazeSIP--EastmanChemicalCompany-.>..-.----~Believethat theoutdateforcompletionofrepowering(ifchosen)shouldbeDecember31,2018,notJuly31,2018asproposedin thepermit.Believethatthecomplexityandenormityofre-powering(ifchosen)warrantsthemaximum amountoftimepossibletodotheproject. Clarificationsoughtinthenarrative'scharacterization of alternativeBART'Semissionrateof0.0006Ib.SOZ/MMBtuasillustrativeonlyandnotanenforceablelimit.CitethatitismerelyanAP-42emissionfactorderivedestimatetocompareBARTandAlternativeBART.SupplementalCommentsin aMay7,20121:56PMCentralTimeEmailfromSteveGossetttoQuincyStyke:Thefirstistoclarifythatifaboilerisnotconvertedtonaturalgasbythecompliancedeadline,itmaynotbeoperatedon coalafter thedeadlineuntiltheconversioniscomplete.Thesecond isthat,consistentwithourinitialcomments,we believeDecember31,2018definestheendofthefirst planning period.IfEPAdisagreeswiththatbelief,thatissuecouldbeopenedup for publiccomment duringEPA'sSIPapprovalprocess.CommentOne:TDEC-APChasresearchedtheissueofJuly31,2018v.December31,2018asbeingtheenddate ofthefirst longtermplanning period of thefederal regionalhazeprogram.TDEC-APCconcludesthatthereisevidenceonbothsidesfortheendingdateandthatonlyEPAorthecourtscandecidewhatthetrueenddatewillbe.TDEC-APCdoesbelievethatEastmanmakesacogentcaseforasmuchtimetoconductre-powering(ifchosen)aspossible duetothemany variablesthatcomprisethecomplexityandenormityof the re-poweringproject.Assuch,TDEC-APChasinserted newlanguageintothe permitatCondition4(fJ{ii)tostatethat the outdatewillbeDecember31,2018ornolaterthantheendoftheperiod ofthefirst long-termstrategyforregionalhazeasdeterminedbyEPA,whichevercomesfirst.TDEC-APCisformally requestingthat€PAprovide final clarityregardingthis dateinits rulemakingthatfinalizesitsstanceontheEastmanBARTandBARTAlternativeSourceSpecificSIPRevisionPermit. IfEPAshouldformallychooseadateotherthanDecember31,2018,itwillbecometheruling outdate.Comment Two:TDEC-APCagreesthattheSIPnarrativeusedthevalueof0.0006Ib.SUZ/MMBtufor illustrativepurposesonlyandisnottobeconstruedasanemissionlimitation.TDEC-APCdirectsthereader'sattentiontoCondition4(b)where constructionpermitapplicationsaredescribedasbeingnecessarytoestablishemissionlimits.Thepermit,notthenarrative itself,istheenforceablecomponentofthisaction.TDEC-APCalsodeclaresthatfor thepurposesof determiningifrepoweringhadtimelyoccurred,shouldaboilerbedown forconversion,but notoperateduntiltherepoweringhad beencompleted,then a timelyrepowering wouldbeconsideredtohaveoccurred.Public HearingComment SummaryBART&AlternativeBARTSource SpecificSIPRevisionPermitForInclusionIntoTheTennessee RegionalHazeSIPEarthJusticeEnvironmentalProtectionAgencyWould liketoseeadeclarationfromEastmannotlaterthanApril30,2017whichoptionitwaspursuingtofulfillitsvisibility impairingpollutantobligations-BARTorAlternativeBART.Would liketoseearequirementthatifrepoweringtonaturalgasischosen,constructionshallcommencenotlater thanApril30,2017 andrepoweringshallbecompleted no later thantheearlierofthecompliancedeadlineoftheone-hoursulfurdioxideNAAQSorJuly31,2018.ExpecttoactpromptlyontheSIPamendment whenfinalized andsubmittedtotheAgency.WillreachafinalconclusionregardingtheadequacyoftheState'ssubmission whenitissubmittedtothem infinalformandtheycompletetheirpublic noticeandcomment rulemakingprocess.AgreewithTDEC-APCthat theAlternativeBARTmeasureproposedforEastmanresultsingreaterprogress(thanBART)inimproving visibilityattheGreatSmokyMountains NationalPark.Thelongterm(after2018)impactof therepoweringtonaturalgasBARTalternativewillbeloweremissionsofsulfurdioxidethantheoriginalBART.TheycommendEastmanforitswillingnesstoact onBARTin2008andtheysupporttheproposedBARTAlternativeforEastmannow..--ACommentOne:TDEC-APChasmodifiedthepermitinCondition4(e)torequirethatintheeventthat therepoweringoptionischosen,constructionmustcommencenolater than April30,2017withathirtydaydeadlinetofilenoticethat thestartofconstruction didoccur.CommentTwo:TDEC-APChasconsideredthecommentsofbothEarthJusticeandEastmaninarrivingatthepositionofhavingnewlanguageproposedatCondition4(f)(ii).That languagehas anoutdateofDecember31,2018,butitprovidesthatifEPAlater determinesthatlesstimeisavailableinthefirstlongtermstrategyperiod,thatamountoftimewouldbecometheoutdate giventoEastmantocompletetherepowering.EEC-AT?concurswith bothcommentsoftheEnvironmentalprotectionAgency.TDEC-APCconcurswith bothcommentsof theNationalParkService.

# Eastman Chemical Company Comments submitted April 23,2012, and May 7,2012

# -
iastman Chemical Company 

# EASTMAN P.O. Box 51 1 Kingsport, Tennessee 37662

April 23, 2012

CERTIFIED MAIL

Mr. Barry Stephens, Technical Secretary Tennessee Air Pollution Control Board 

### gthFloor, L&C Annex 401Church Street Nashville, Tennessee 37423-1531
Subject: Proposed Amendments to the Tennessee Regional Haze State lmplementation Plan

Dear Mr. Stephens:

In responseto the notice of public hearing announced by the Tennessee ~epartmenrof Environment and conservation on April 4,2012, Eastman Chemical Company (Eastman) submits the following comments on the proposed amendments to the Tennessee Regional Haze State lmplementation Plan (SIP). These am'endments propose an alternative Best Available Retrofit Technology (BART) determination for Eastman's Tennessee operations in Kingsport, Tennessee.

This alternative involves conversion of Eastman's Building 253 coal-fired powerhouse from coal to ' natural gas. The federal BART regulations allow an alternative measure to be included in a SIP revision 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 inthe 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 Eastmanto complete the project, which clearly provides significantly greater progress in reduction of visibility impairment in Class IAreas.

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. Referenceswe 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-@Regional Haze State Implementation Plan for Tennessee Class l Areas, dated April 4, 2008. Section 7.0 of this plan describes the long-term strategy:

'This first set of reasonable progress goals must be met through measures contained in the state's long-term strategy covering the period from the baseline until 2018.

The regional haze SIP proposed and final actions EPA has been taking all define the planning periods as 10 year periods starting 20014 and ending in 2064, with the first period including the calendar years 2009 through 2018.

The proposed rule approving Colorado's regional haze SIP revision included an alternative programthat achieves greater reasonable progressthan BART. When addressingthe requirement that all emission reductions take place during the first planning period, EPA states:

"Pursuant to 40 CFR 51.308(e)(2)(iii), Table25 shows that all controls under the BART alternative will occur by December 17,201 7, within thefirst planning period, which ends in December 2018." (emphasis added)

Therefore, we believe it is clear that the first planning period ends December 31, 2018. We request the deadline for completion of the emission reductionsfrom implementing the alternative measure be changed from July 31,2018 to December 31,2018.

In addition to the plain language above indicating EPA intended the first planning period to end on December 31,2018, there are additionaljustifications 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 atthe 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 ofthe detailed engineering required for such a modification has been performed. This means that Eastman has a basis for believingthat the boilers can be converted to fire natural gas, but has very little visibility about the extent oftechnical 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 considerabletechnical 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 3technical risks requires time in order to ensure that what is learned from the first unit to undergo such a conversion can be incorporated into the design and checkout of the subsequent four units. This will
ensure that the potential conversion of any of these boilers is not only good for the environment, but is also good business risk for Eastman and that the unit is safe for plant personnelto operate.

Third, one of the most critical success factors for a potential conversion is completely beyond Eastman's control. Shifting approximately half of the Kingsport site's energy infrastructure to natural gas requires
a major expansion to many miles of interstate pipeline. Expanding interstate gas pipelines is regulated by the Federal Energy Regulatory Commission (FERC), which has a rigid public process to ensure the interests of the public are protected. The FERC process has to be followed to its conclusion before the
owner of the pipeline can set the cost charged to Eastman for expanding the pipeline. If Eastman concludes that the cost is reasonable and supports the business case for converting to natural gas, only then will the pipeline owner begin the project to engineer and physically modify the pipeline to carry the additionalvolume of gas. Eastman made broad assumptions about the duration of the FERC approval process and the pipeline engineering and construction when it concluded that converting coal fired boilers to fire natural gas was feasible within the first Regional Haze planning period. But it is well known that Eastman is not the only company considering changes that will require expansions to interstate pipelines, and these changes could impact the timing of pipeline expansions to support the Kingsport site, For example, American Electric Power recently announced its intent to convert portions of itsClinch River Plant in Cleveland, Virginia (approximately50 miles from Kingsport, and fed from the
same interstate pipeline that services Kingsport), from coal to Natural 

## k as'. The timing of the FERC process, the pipeline owner's engineeringand construction process, or the influence of other companies could impact the date that natural gas is available to Eastman in Kingsport. Because none of these factors can be known with certainty, each introduces both cost and schedule risk. Yet despite the fact 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 ofTennessee'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 ofthe gas nor by the pipeline companies that transport the gas. The figure cited above issimply 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 emissionsfrom 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.

Ifyou have any questions concerningthese comments, please contact me at (423)229-2327.



## step hen'^. ~osskt, P.E. Environmental Fellow <

1 AEP Shares Plan For ComplianceWith Proposed EPA Regulations, June 9,2011, http://www.aep.com/newsroom/newsreleases/?id=1697
Eastman Comment Page 3 of 3

### From: Gossett, Stephen R 

### [mailto:srgosset@eastman.com] 

### Sent: Monday, May 07, 2012 1:56 PM 

### To: Quincy Styke; 

### 'Benjamin.Lynorae@epamail.epa.gov' 

### Cc: Travis Blake; Barry Stephens; Lacey Hardin; Sago, Brett A. 

### Subject: BART Alternative - Supplemental Eastman Comments

Please accept this email as supplemental Eastman comments.

First, I have attached marked up revisions to the latest TDEC draft permit language. Two issues
are addressed.

The first is to clarify that if a boiler is not converted to natural gas by the compliance deadline, it may not be operated on coal after the deadline until the conversion is complete.

The second is that, consistent with our initial comments, we believe December 31,2018 defines the end of the first planning period. If EPA disagrees with that belief, that issue could be opened up for public comment during EPA1sSIP approval process.

### Page 3 of 3



### (ii)

# Earth Justice Comments submitted April 23,2012 (via EPA) and May 7,2012

### Travis 

## Blake

From: Sent: To: Subject: 

### Lacey Hardin Monday, May 14,201 2 754AM Travis Blake 

### FW: Comments from the Litigants on Proposed Tennessee Regional Haze SIP Importance: 

### High

-----------------.- ---.----., ----- -.--.----....- -- .------.I 

### __. .___ 

### From: Quincy Styke 

### Sent: Wednesday,-April 25, 2012 9:20 AM 

### To: Travis Blake; Lacey Hardin; Gosset, Steve 

### Cc: Quincy Styke 

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

### Importance: High

I'm going to be in an all day meeting. Look these over and see what changes we would be likely to make in response to the comments. Maybe we could chat late this afternoon



## .... Quincy I11



### From: Lynorae Benjamin 

### [Benjamin.Lynorae@epamail.epa.gov] 

### Sent: Monday, April 23,2012 6:lO PM 

### To: Barry Stephens; Quincy Styke 

### 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 repoweringto 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 correspondingto the time frames shown in Table 2 of the SIP revision. Sequential deadlines are particularly important given that the final deadline (July2018) is more than a year past the original BART deadline of April 2017. 

### 2. The draft permit is written inconfusing 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 draftpermit actually has two Condition 4's 

### - I assume here the intent was to reference the first of these). But no where does Condition 4 expressly require Eastman to elect one option or the other by a date certain. Condition4(c) merely says that "if" the permittee determines that the repowering option is not feasible, it shall submit written notification to the state and 

### - EPA, and upon that submission the permittee,shall comply with the original BART by 7-30-17. Condition 4(e) says that 

### "iP' the permittee elects to repower its 8-253 Powerhouse boilers to natural gas, the conversion shali be done by the deadlines specified. These provisions don't require Eastman to make any election at all, much less set a deadline for doing so. The only action that Eastman has to take under Condition 4 -absent election of one option or the other 

## - is submit reports. This is unacceptable. The permit or other SIP provisions must require in explicit, unambiguous, and legally enforceable terms that Eastman must implement one option or the other by the relevant deadlines, and must notify the state and EPA of its election by a date certain deadline. Given that the modeling exercise is supposed totake no more than year, a logical deadline for making the election would be no later than July 1,2013 -a year after the first progress report.

The above concerns need to be addressed in order for us to acceptan extension to November for final action on BART for this facility. Any thoughts on how best to deal with these issues?

### From: David Baron [dbaron@earthjustice.org] 

### Sent: Monday, May 

### 07, 2012 9:08 AM 

### To: Quincy Styke 

### Cc: gtderson.lea@em.aov; Vera Kornylak 

### (Kornvlak.Vera@emmail.e~a.aov); Eric Triplett 

### (Tridett.EricBe~amaiI.eoa.aov) Suuect: Eastman

Mr. Styke,

Attached are edits to the draft Eastman permit to address our concerns, consistent with the discussion last Thursday. With these changes, the proposed SIP revision (April 4,2012) would be
an acceptable compromise for our clients.

Let me know ifyou have questions about this approach. Feel free to share this draft with Eastman and other interested parties.

David Baron

David Baron 

### Managing Attorney Earthjustice 

### 1



### 625 Massachusetts Avenue, 

### NW, Suite 702 Washington, 

### DC 20036 

### (202) 

## 667-4500 Ext. 5203 (phone) 

### (202) 

### 667-2356 (fax) dbaron8earthiustice.ora <mailto:dbaron @earthiustice.ora>

# EPA 

# Comments

### UNITED STATES 

### ENVIRONI#EWTAL PROTECTIOM

### AGE CV REGIONI 

### ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, 

### GEORGIA 30303-8960


### May 7,2012

Robert J. Martineau Commissioner Tennessee Department of

Environment and Conservation 401 Church Street L&C 

### Annex, 1 st Floor Nashville, Tennessee 37243

Dear Mr. Martineau:

The U.S. Environmental Protection Agency 

## has completed a preliminary review of the Tennessee Department of Environmental Conservation's (TDEC's) proposed amendment to the State's regional haze state implementation 

### plan (SIP), 

## as received via email from 

### Mr. Barry Stephens on April 4,2012. The amendment would establish 

## an alternative emission reduction measure to best available retrofit technology (BART) for Eastman 

### Chemical Company's B-253 Powerhouse in Kingsport, Tennessee. The 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

# National Park Service Comments

### Travis Blake

From: 

### Sent: To: 

### Subject: Lacey Hardin Monday, May 14,2012 7:51 AM Travis Blake FW: Proposed Revisions to Tennessee's Regional Haze 

### SIP



## ----- Original Message----- From: Patricia F Brewer@nps.~ov [mailto:Patricia F Brewer@nps.gov] Sent: Wednesday, April 18, 2012 9:48 AM To: Barry Stephens; Quincy Styke; Lacey Hardin
- - - - - - -- Cc: 

### 'baanderson02@fs.fed.usn; Beniamin.L~noraePe~amail.e~a.gov; 'DonShepherd@nps.govl; Haidar Alrawi; 'Tim-Allen@fws.gov'; Susan Johnson@nps.aov Subject: Re: Proposed Revisions to Tennessee's Regional Haze SIP
Barry and Quincy,



### I have reviewed the attached documents on Tennessee Eastman. National Park Service concurs with Tennessee Eastman's proposal to investigate switch to natural gas as BART alternative. We understand the schedule implications.

Tennessee Eastman stepped forward in 2007-2008 to accept BART controls. We want to work with good neighbors to achieve visibility improvements.

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<Haidar.Alrawi@tn.aov>, Barry Stephens 

### <Barrv.Stephens@tn.gov>, Quincy Styke <Quincy.Styke@tn.gov> Subject Proposed Revisions to Tennessee's Regional Haze SIP

All,

Please find attached the proposed revisions to Tennessee's Regional Haze SIP for your review and comment. The public comment period begins April 5 and ends May7. Please feel free to contact Quincy Styke, Haidar Alrawi, or me at 

### 615-532-0554 if you have any questions.
Lacey Hardin Assistant Director Tennessee Department of Environment and Conservation Division of Air Pollution Control[attachment "Public Notice.docx" deleted by Patricia F Brewer/DENVER/NPS] [attachment "Regional Haze Alternative 

### BART-Eastman-4-4-12.pdf" deleted by Patricia F Brewer/DENVER/NPS]

# United 

# States 

# Department 

# of the Interior

NA 1 IONAL. 

### PARK SERVK'E Air Resources Divisian P.O. Box 35287 Dsl~vrr. C(:) 80225-0287



### May 4,2012

Barry Stephens, Director Air Pollution Control Division Tennessee Department of Environment and Conservation 9"' 

### Floor, 

### L & 

### C 

### Annex 401 Church Street Nashville, 

## TN 37243



### Dear Mr. 

### Stephens:

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 2018, 

### sulhrdioxide 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.

### We appreciate the opportunity to work closely with TDEC and the US. 

### Environtncntal Protection Agency to make progress toward achieving natural visibility conditions at our National Parks and 

### Wilderness Areas. 

### For further information regarding our comments, please contact Pat Brewer at (303) 

### 969-2 153.


### Sincerely,



### Susan Johnson Chief, Policy, Planning, and Permit Review Branch

CC 

### : 

### Beverly Banister, Director Air, Pesticides, and 

### Toxics Management Division U.S. Environmental Protection Agency, Region 4 

### 61 Forsyth Street, 

### SW Atlanta, GA 30303-8960

# Attachment 4



# BART Permit 066116H

### DEPARTMENT OF ENVIRONMENT 

### AND CONSERVATION NASHVILLE, TENNESSEE 

### 37243- 

### 1531



### OPERATING PERMIT Issued Pursuant to. Tennessee Air Quality Act Date Issued: May 9,2012 

### Permit Number:

0661 16H


### Date Exoires: December 3 

### 1,20 1 8

Eastman Chemical Company Tennessee Operations (MSOP-02) 

### Installation Address:

SouthEastman Road Kingsport



### Installation Description:

Powerhouse B-253- 

### 1, Boilers #25-#29 

### Emission SourceReference No.

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:

1. In accordance with the requirements of 40 CFR 

### 5 1.308 (BART), the following emission limitationis established:

Sulfur dioxide (SOz)emissions from Boilers 25-29 shall comply with the less stringent of the following limits:
0.20 pounds of SO2per million British Thermal Units (IblMMBtu) of heat input; or

Reduce uncontrolled SO2emissions 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 SO2reduction, from either each boiler individually while combusting coal, or averaged across all of the boilers that are combustingcoal.
(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

### Page 2 of 3

2. Monitoring Requirements:

Measurement of SO7emissions: SO2emissions shall be measured through the use of continuous in-stack monitoring for sulfur dioxide, as ~~ecifiedbelow:

The source owner or operator shall install, maintain, operate, and submit quarterly reports of excess emissions and sulfur dioxide (SO2) removal efficiency (if applicable) from continuous in-stack monitoring systems for sulfur dioxide (SOz). The sulfur dioxide monitoring systems shall meet all the requirements of 40 CFR 

### 60 Appendices A and B, or 40 

### CFR Part 75 

### Appendices A and F.
Compliance will be 

### determined on a 30 calendar day rolling average basis. Each 30 calendar day average shall be 

### the average of the valid daily averages during the previous thirty (30) calendar days
Operational requirements for Sulfur Dioxide 

### (S07) Monitoring Systems: For this fuel burning installation to demonstrate continual compliance with the BART sulfur dioxide emission limitation, each sulfur dioxide monitoring system for boilers #25- #29 shall be fully operational for at least ninety five percent (95%) of the operational time (during which coal is combusted) of the monitored 

### units during each calendar quarter. Operational availability levels of less than these amounts may be 

### considered the basis for declaring the fuel burning installation in noncompliance with the applicable monitoring requirements, unless the
reasons for the failure to maintain these levels of operational availability are accepted by the Technical Secretary as being legitimate malfunctions of the instruments. Data recorded during periods of monitoring system breakdown, repairs, calibration checks, and zero and span adjustments shall not be included in the data averages.

ualitv Assurance reauirernents for the Sulfur Dioxide (SO,) Monitoring Systems: The continuous in-stack sulfur dioxide zonitoring systems shall meet all of the requirements of 40 C% 

### part 60 Appendix B (Performance Specification2) 

### and 40 CFR 

### Part 60 Appendix 

### F; or 40 CFR Part 

### 75 Appendices A and B.


### MonitoringPlan: Monitoring shall be conducted as specified 

### in an approved site-specificmonitoring plan. The monitoring plan must be submitted to the 

### TechnicalSecretary at least ninety (90) days prior to the startupof 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 1and 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.

### 0661

### 16H 

# CI r) Page 3 of 3



### The permittee shall submit applications for any construction permit(s) as needed to establish emission limits and other applicablerequirements to repower the boilers.

If the permittee determines that AlternativeBART is not feasible for this facility, the permittee shall provide written notification to the Technical Secretary and the 

### EPA Region 4 

### Office in a final quarterly report. Upon submittal of this notification, the permittee shall comply with Conditions 1and 2 of this permit no later than April 30,2017.

The permittee is placed on notice that the issuance of this permit does not excuse it from any other applicable air pollution control requirements that may become applicable as a result of repowering to natural gas.
(e) If the permittee elects to repower 

### its B-253 Powerhouse boilers to natural gas, the permittee shall begin actual construction (as defined in Rule 1200-03-09-.01(4) 

### of 

### the Tennessee Air Pollution Control Regulations) on the conversion-no-later

### than April 30, 2017. 

### The 

### permittee shall provide written notice to the Technical Secretary no later 

### than 

### thirty (30) days 

### following 

### the sbt 

### of actual 

### construction.

If the permittee elects to repower its B-253 Powerhouse boilers to natural gas, the conversion shall be accomplished (or else an unconverted boiler not operated until converted) no later than the earlier of:
(i) The compliance deadline for the one-hour sulfur dioxide NAAQS, 

### or (ii) December 31, 

### 2018, or the end of the period of the first long term strategy for regional haze as determined by U. S. 

### EPA, whichever is earlier.

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 557888is reopened to include the requirements of this permit.
(end of conditions)

# Attachment 

# 5

Board Order 12-008

### STATE OFTENNESSEE AIR POLLUTION CONTROL 

### BOARD

IN THE MATTER OF: 

### 1 1 STATE IMPLEMENTATIONPLAN APPROVAL 

### 1 REGIONAL HAZE 

### - CLASS I VISIBILlTY IMPAIRMENT ) 

### ORDER NO. 12-008



### BOARD 

### ORDER
Regional haze is pollution 

### that impairs visibility over a large region, including national parks, forests, and wilderness areas (Class I areas). Regional 

### haze is caused by sources and activities emitting 

### fine particles and precursors such as SOz, which affect visibility through 

### the scattering 

### and absorption of 

### light and 

### may be tansported over long distances. Reducing fine particles 

### in the atmosphere 

### is an effective method of 

### improving visibility. In the southeast,the most important sources of hazeforming emissions are coal-fued power plants, industrial boilers and other combustion sources.

40 

### CFR 85 1.308(e)

### requires affected States to submit 

### an implementation plan containing emission limitations and schedules for compliance representing 

### Best Available Retrofit Technology 

### (BART) for each BART-eligible source that may reasonably be anticipated to cause or contribute to any impairment of visibility 

### in any 

### mandatory Class I Federal area. To address the 

### requirements for 

### BART,the State 

### must submit 

### an implementation

### plan 

### containing the plan elements 

### specified in 85 1.308(e)(l) 

### and indude 

### docmentation l%r 

### all required analyses. Affected sources 

### are required 

### to 

### install and operate BART no later than 

### five years after approval of 

### the implementation

### plan revision. On April 4,2008, the Board approved the Regional Hale State 

### Implemntation Plan for Tennessee Class I Areas, 

### including 

### BART requirements for Eastman Chemical Company, for submittal 

### to 

### U. S. EPA far adoption 

### into Tennessee's StateImplementationPlan.

Pusuant to $5 

### 1.308(e), States may opt to implement alternatives to BART, provided that the alternativemeasure must achieve greater reasonable progress than would 

### be achieved through 

### the installation and operation of BART. For such alternative measures, the State 

### must submit an 

### implementatignplan containing the plan elements specified in 851.308(e)(2) and include documentation for a11 required analyses. 

### A11 

### required emission reductions that 

### are required pursuant to 85 1.308(e)(2) must take 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 

### (BARTpermit for 

### Eastman Chemical Company issued March 3 

### 1,2008). The Board approves the submittal of the AItelllatrmve 

### BARTDetermination 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