west virginia department of environmental protection

Appendix B: 

Interagency Consultation

Promoting a healthy environment.

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 1
[This page intentionally left blank.]

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 2
Table of Contents

60-Day Consultation Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 5

Letter Re: WV Regional Haze Rule Periodic Update Consultation with FLM Agencies, from

William Durham , Deputy Director, DAQ to:

Ms. Susan Johnson (National Park Service), 

Ms. Sandra V. Silva (U.S. Fish & Wildlife Service), 

Mr. Clyde N. Thompson (U.S. Forest Service), 

Mr. Chuck Sams (U.S. Forest Service), 

cc’d to Tim Allen (U.S. Fish & Wildlife Service), 

Patricia Brewer (National Park Service), 

John Hornback (Metro 4/SESARM), 

Melissa Linden (U.S. EPA Region 3), 

Anthony Matthews (National Forests in Florida) . . . . . . . . . . . . . . . . . . . . . . . . . . Page 7

Email Subject: Draft WV Regional Haze 5-year Periodic Review, from William Durham, Deputy

Director, DAQ to:

Anthony Matthews (National Forests in Florida), 

Bret Anderson (U.S. Forest Service), 

Chuck Sams (U.S. Forest Service), 

Clyde Thompson (U.S. Forest Service), 

Patricia Brewer (National Park Service), 

Sandra V. Silva (U.S. Fish & Wildlife Service), 

Susan Johnson (National Park Service), 

Tim Allen (U.S. Fish & Wildlife Service)

Melissa Linden (U.S. EPA Region 3)

Tom Ballou (VA DEQ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 9

Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 11

Email Subject: Draft WV Regional Haze 5-year Periodic Review, from Jacqueline Lewis, US

EPA Region 3 to Laura Crowder, DAQ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 13

Memorandum Subject NPS Comments WV Five Year Progress Report, from Pat Brewer, NPS

Air Resources Division to Laura Crowder, WV DEP . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 17

Letter from Sandra V. Silva, Chief , Branch of Air Quality, Fish and Wildlife Service to William

Fredrick Durham, Deputy Director – Air Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19

Response to Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21

Federal Land Manager Consultation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 3
[This page intentionally left blank.]

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 4
60-Day Consultation

Communications

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 5
[This page intentionally left blank.]

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 6
Division of Air Quality

601 57th Street SE

Charleston, WV 25304

Phone: (304) 926-0475

west virginia department of environmental protection

Earl Ray Tomblin, Governor

Randy C. Huffman, Cabinet Secretary

www.dep.wv.gov

January 4, 2013

Ms. Susan Johnson Ms. Sandra V. Silva

Policy, Planning and Permit Review Branch Chief, Air Quality Branch

National Park Service U.S. Fish and Wildlife Service

PO Box 25287 7333 W. Jefferson, Suite 375

Denver, CO 80235-2017 Lakewood, CO 80235

Mr. Clyde N. Thompson Mr. Chuck Sams

Forest Supervisor, Monongahela National Forest U.S. Forest Service

U.S. Forest Service 1730 Peachtree Road, NW

200 Sycamore Street Atlanta, GA 30309

Elkins, WV 26241

Re: WV Regional Haze Rule Periodic Update Consultation with FLM Agencies

Dear Federal Land Manager (FLM) Partners:

The 1999 Regional Haze Rule (RHR) requires States to develop State Implementation Plans (SIPs)

to reduce visibility impairment with the express intent that by 2064 the visibility in all Class I areas

will be returned to natural conditions. The RHR also requires the State to consult with the Federal

Land Management agencies at least 60 days prior to holding any public hearing on a RHR SIP or

SIP revision (40CFR51.308(i)). We believe that such consultation can be sufficiently accomplished

via phone or written communication, including email and/or letter. However, if your agency desires

an in-person consultation or teleconference, please advise us as soon as practicable, but no later than

30 days after receipt of this submittal.

The West Virginia Department of Environmental Protection (DEP) submitted its original Regional

Haze SIP to the U.S. Environmental Protection Agency (EPA) on June 18, 2008. On March 23,

2012, the EPA published a final rule granting limited approval (77FR16937) of West Virginia’s

Regional Haze SIP. EPA identified a general deficiency related to the federal Clean Air Interstate 

Rule for most, if not all, states in the eastern United States, even though most controls in West

Virginia were required by mechanisms other than CAIR. As subsequent litigation has unfolded, EPA

has acknowledged that CAIR is still in place and will be for the near future. In any event, most of

the controls that CAIR required have been implemented and continue operating. It should be noted 

Promoting a healthy environment.

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 7
WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 8
1

Crowder, Laura M

From: Durham, William F

Sent: Friday, January 04, 2013 11:15 AM

To: 'Anthony Matthews'; 'Bret Anderson'; 'Chuck Sams'; 'Clyde N. Thompson'; 'Patricia 

Brewer'; 'Sandra V. Silva'; 'Susan Johnson'; 'Tim Allen'; 'Melissa Linden 

(linden.melissa@epa.gov)'; 'Tom Ballou (trballou@deq.virginia.gov)'

Cc: Crowder, Laura M; 'Mike Abraczinskas (michael.abraczinskas@ncdenr.gov)'; 

'masonmr@dhec.sc.gov'; 'doris.mcleod@deq.virginia.gov'; 'Ron Methier'; 'John 

Hornback (hornback@metro4-sesarm.org)'; 'John Gowins (john.gowins@ky.gov)'; 

'Quincy Styke'; 'Haidar.Alrawi@tn.gov'

Subject: Draft WV Regional Haze 5-year Periodic Review

Attachments: William Frederick Durham.vcf; WV RH Midcourse review 2013-01-02.pdf

Dear Federal Land Manager (FLM) Partners: 

The 1999 Regional Haze Rule (RHR) requires States to develop State Implementation Plans (SIPs) to reduce

visibility impairment with the express intent that by 2064 the visibility in all Class I areas will be returned to

natural conditions. The RHR also requires the State to consult with the Federal Land Management agencies at

least 60 days prior to holding any public hearing on a RHR SIP or SIP revision (40CFR51.308(i)). We believe

that such consultation can be sufficiently accomplished via phone or written communication, including email 

and/or letter. However, if your agency desires an in-person consultation or teleconference, please advise us as

soon as practicable, but no later than 30 days after receipt of the hardcopy submittal. 

The West Virginia Department of Environmental Protection (DEP) submitted its original Regional Haze SIP to

the U.S. Environmental Protection Agency (EPA) on June 18, 2008. On March 23, 2012, the EPA published a

final rule granting limited approval (77FR16937) of West Virginia’s Regional Haze SIP. EPA identified a 

general deficiency related to the federal Clean Air Interstate Rule for most, if not all, states in the eastern United

States, even though most controls in West Virginia were required by mechanisms other than CAIR. As

subsequent litigation has unfolded, EPA has acknowledged that CAIR is still in place and will be for the near

future. In any event, most of the controls that CAIR required have been implemented and continue operating. It

should be noted that approximately 88% of the current electric generating capacity in the State is controlled by

Flue Gas Desulfurization (FGD) to significantly reduce sulfur dioxide emissions, which form sulfates, the

dominate contributor to regional visibility impairment in the southeast, including West Virginia. 

The RHR at 40 CFR 51.308(g) requires periodic reports evaluating progress towards the reasonable progress

goals established in the SIP. The first progress report is due five years from submittal of the initial SIP, or June

18, 2013. DEP has prepared the attached draft periodic update for the Dolly Sods and Otter Creek Wilderness

Areas. Please assist the DEP in starting West Virginia’s required 60-day consultation period. 

Today DEP is sending, via express courier, packages to each FLM office that include the draft SIP with full 

electronic supporting documentation. Please acknowledge the date of said package receipt as the formal

commencement of the required 60-day review period. We would appreciate your formal comments on or before

March 8, 2013. Should you have any questions concerning West Virginia’s regional haze SIP development,

please contact Laura Crowder of my staff at (304) 926-0499 ext. 1247 or Laura.M.Crowder@wv.gov. The SIP 

narrative is attached in PDF. 

Sincerely, 

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 9
2

Fred Durham 

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 10
Comments

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 11
[This page intentionally left blank.]

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 12
1

Crowder, Laura M

From: Lewis.Jacqueline@epamail.epa.gov

Sent: Thursday, January 31, 2013 4:08 PM

To: Crowder, Laura M

Cc: Mastro.Donna@epamail.epa.gov

Subject: Draft WV Regional Haze 5-year Periodic Review

Hi Laura, 

Please find below EPA Region 3's comments on your draft Regional Haze 5-Year Progress Report. If you have any 

questions I can be reached at the number below. 

Section 1.1.c. Nonroad Diesel Emissions Program (40 CFR Part 89) 

There is a typo in the 2nd paragraph, the word form should be from. 

Section 1.6 Reasonable Progress Determinations 

Please add the status of Capital Cement Kilns 8 and 9 to this section. Table 3 of Section 1.5.a. indicated that 

Kilns 7, 8 and 9 were shutdown in 2009. 

Section 2.1 Mercury Air Toxics Rule 

There is a typo in the 2nd paragraph, last sentence the Federal Register citation should be 77 FR 9304. There is 

also a typo in the 3rd paragraph, 1st sentence the letter “o” is missing from the word power. 

Section 2.6 Federal Consent Decrees 

Please include the compliance date for INVISTA and the shutdown date for the sulfuric acid manufacturing unit 

at DuPont and Lucite International. 

Section 2.7 West Virginia Unit Specific Point Source Reductions 

Table 6 list Capital Cement’s Kiln 7, should Kiln 8 be included in this table? 

Section 3.1 EGU Reductions 

Table 7 list the facilities outside of West Virginia with a calculated visibility impact greater than 0.5% on Dolly 

Sods, please add the state where the facilities are located. 

There is a typo in the 1st paragraph under Figure 5, for consistence the letter “b” in Tbtu should be capitalized. 

Section 3.3 EGU Unit Specific Reductions 

Please indicate the shutdown dates for units 7 and 8 at the Rivesville facility in Table 10. 

Section 8 Assessment of Monitoring Strategies 

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 13
2

There is a typo in the 1st paragraph above Figure 26, in the 1st sentence the letter “t” in the word filter is 

missing. 

Thanks 

Jacqueline Lewis, 

Environmental Engineer 

U.S. Environmental Protection Agency, Region 3 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

(215) 814-2037 

lewis.jacqueline@epa.gov ----- Forwarded by Jacqueline Lewis/R3/USEPA/US on 01/31/2013 03:57 PM ----- 

From: "Durham, William F" <William.F.Durham@wv.gov> To: Anthony Matthews <jmatthews@fs.fed.us>, Bret Anderson <baanderson02@fs.fed.us>, Chuck Sams <csams@fs.fed.us>, "Clyde N. Thompson" 

<cnthompson@fs.fed.us>, Patricia Brewer <Patricia_F_Brewer@nps.gov>, "Sandra V. Silva" <Sandra_V_Silva@fws.gov>, Susan Johnson 

<Susan_Johnson@nps.gov>, Tim Allen <Tim_Allen@fws.gov>, Melissa Linden/R3/USEPA/US@EPA, <trballou@deq.virginia.gov> Cc: "Crowder, Laura M" <Laura.M.Crowder@wv.gov>, <michael.abraczinskas@ncdenr.gov>, <masonmr@dhec.sc.gov>, <doris.mcleod@deq.virginia.gov>, 

Ron Methier <ronmethier@comcast.net>, <hornback@metro4-sesarm.org>, <john.gowins@ky.gov>, Quincy Styke <quincy.styke@tn.gov>, 

<Haidar.Alrawi@tn.gov> Date: 01/04/2013 11:16 AM Subject: Draft WV Regional Haze 5-year Periodic Review 

Dear Federal Land Manager (FLM) Partners: 

 

The 1999 Regional Haze Rule (RHR) requires States to develop State Implementation Plans (SIPs) to reduce 

visibility impairment with the express intent that by 2064 the visibility in all Class I areas will be returned to 

natural conditions. The RHR also requires the State to consult with the Federal Land Management agencies at 

least 60 days prior to holding any public hearing on a RHR SIP or SIP revision (40CFR51.308(i)). We believe 

that such consultation can be sufficiently accomplished via phone or written communication, including email 

and/or letter. However, if your agency desires an in-person consultation or teleconference, please advise us as 

soon as practicable, but no later than 30 days after receipt of the hardcopy submittal. 

 

The West Virginia Department of Environmental Protection (DEP) submitted its original Regional Haze SIP to 

the U.S. Environmental Protection Agency (EPA) on June 18, 2008. On March 23, 2012, the EPA published a 

final rule granting limited approval (77FR16937) of West Virginia’s Regional Haze SIP. EPA identified a 

general deficiency related to the federal Clean Air Interstate Rule for most, if not all, states in the eastern United 

States, even though most controls in West Virginia were required by mechanisms other than CAIR. As 

subsequent litigation has unfolded, EPA has acknowledged that CAIR is still in place and will be for the near 

future. In any event, most of the controls that CAIR required have been implemented and continue operating. It 

should be noted that approximately 88% of the current electric generating capacity in the State is controlled by 

Flue Gas Desulfurization (FGD) to significantly reduce sulfur dioxide emissions, which form sulfates, the 

dominate contributor to regional visibility impairment in the southeast, including West Virginia. 

 

The RHR at 40 CFR 51.308(g) requires periodic reports evaluating progress towards the reasonable progress 

goals established in the SIP. The first progress report is due five years from submittal of the initial SIP, or June 

18, 2013. DEP has prepared the attached draft periodic update for the Dolly Sods and Otter Creek Wilderness 

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 14
3

Areas. Please assist the DEP in starting West Virginia’s required 60-day consultation period. 

 

Today DEP is sending, via express courier, packages to each FLM office that include the draft SIP with full 

electronic supporting documentation. Please acknowledge the date of said package receipt as the formal 

commencement of the required 60-day review period. We would appreciate your formal comments on or before 

March 8, 2013. Should you have any questions concerning West Virginia’s regional haze SIP development, 

please contact Laura Crowder of my staff at (304) 926-0499 ext. 1247 or Laura.M.Crowder@wv.gov. The SIP 

narrative is attached in PDF. 

 

Sincerely, 

 

Fred Durham 

 

 

 

[attachment "William Frederick Durham.vcf" deleted by Jacqueline Lewis/R3/USEPA/US] [attachment "WV RH Midcourse review 2013-01-02.pdf" deleted by 

Jacqueline Lewis/R3/USEPA/US] 

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 15
[This page intentionally left blank.]

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 16
TRANSMITTED VIA ELECTRONIC MAIL - NO HARDCOPY TO FOLLOW

N3615 (2350)

March 6, 2013

Memorandum

To: Laura Crowder, WV Department of Environmental Protection

From: Pat Brewer, NPS Air Resources Division

Subject: NPS Comments WV Five Year Progress Report

As requested, I have reviewed West Virginia Department of Environmental Protection

(WVDEP)’s draft regional haze progress report. I believe that WVDEP has met the 

requirements for the periodic progress report as outlined in 40 CFR 41.508 (g). I agree that 

WVDEP has demonstrated that emissions reductions are on track to meet the 2018 reasonable 

progress goals established in the WV Regional Haze State Implementation Plan (SIP) for Class I 

areas in WV. Further, WV emissions reductions are consistent with assumptions used by 

neighboring states to set reasonable progress goals for their Class I areas. 

I have a few suggestions for you to consider to strengthen the report.

Section 1: Status of implementation measures: Since the majority of sulfur dioxide (SO2) 

emissions reductions are due to electric generating units (EGU), it would make sense to discuss 

EGU before other emission sectors. 

Section 1.2 covers Consent Decrees that were included in the VISTAS Best and Final inventory 

and modeling run. It would be helpful to add reference at the end of that section that consent 

decrees since 2008 are discussed under Reasonable Progress in Section 2.6.

Section 3: Figure 7 demonstrates that actual 2011 EGU emissions were below the projected 

2018 EGU emissions included in VISTAS Best and Final modeling run. Table 10 compares unit 

specific actual controls to controls assumed in VISTAS modeling. Table 11 addresses EGUs

specifically covered in the MANEVU Ask. Can you also summarize the emissions reductions 

and facility shutdowns that would be applicable toward the MANEVU ask for non-EGU SO2

emissions?

United States Department of the Interior

NATIONAL PARK SERVICE

Air Resources Division

P.O. Box 25287

Denver, CO 80225-0287

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 17
2

Section 5: Please provide additional background on the 2007 SEMAP inventory and its 

objectives. The MANEVU draft SIP template provides a good description of the differences 

between the Regional Planning Organization inventories and EPA’s National Emissions 

Inventory (Mobile 6 vs MOVES models, state data vs Integrated Planning Model for EGU 

growth and controls, NEI vs modeling inventory) that you might add/paraphrase in your 

emissions inventory section. 

Section 7: WV Contributions to Class I areas in neighboring states: your analysis identifies WV 

non-EGU that contribute 0.5% to Class I areas in neighboring states. The analysis could be 

strengthened by including the Area of Influence defined through the VISTAS process for each 

Class I area and listing WV EGU and non-EGU in each AoI. How have emissions changed for 

these sources?

We appreciate the opportunity to work closely with WVDEP to improve visibility in our Class I 

national park and wilderness areas. 

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 18
** via e-mail transmission - hard copy will not follow * * 

Mr. William Fredrick Durham Deputy Director -Air Quality West Virginia Department of Environmental Protection 601 57th Street SE 

Charleston. West Virginia 25304 Dear Mr. Durham: On January 4,201 3, the State of West Virginia provided a draft 5-year progress report for the 

State's Regional Haze State Implementation Plan (SIP). Although the U.S. Fish and Wildlife Service (FWS) does not have Class I areas within West Virginia, the draft and appendices 

include all of the necessary elements and information needed to adequately address regional haze 

progress at our nearby Class I Refuges. The documents were comprehensive and well written to accommodate a full review. We agree with the State's conclusion of "negative declaration" and 

do not request further revision to West Virginia's Regional Haze SIP. This letter acknowledges that the U.S. Department of Interior, FWS, has conducted a substantive 

review of the draft Regional Haze SIP revision in fulfillment of the requirements identified in 40 

CFR 51.308(i). Please note that only the U.S. Environmental Protection Agency (EPA) can 

make a final determination regarding the document's completeness and, therefore, ability to receive federal approval from EPA. It is noteworthy that West Virginia is one of the first States to submit a draft 5-year progress 

report to the FWS for review. We compliment you on your hard work and dedication to the 

significant improvement in our nation's air quality related values and visibility. 

Sincerely, 

dandra V. Silva w Chief, Branch of Air Quality 

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 19
[This page intentionally left blank.]

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 20
Response to Comments

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 21
[This page intentionally left blank.]

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 22
Federal Land Manager Consultation

The Regional Haze Rule at 40 CFR §51.308(i)(2) requires that the State “provide the Federal Land

Manager with an opportunity for consultation, in person and at least 60 days prior to holding any

public hearing on an implementation plan (or plan revision).” In accordance with these requirements,

the West Virginia Department of Environmental Protection, Division of Air Quality (WVDAQ) sent

a draft of the West Virginia State Implementation Plan Revision: Regional Haze Periodic Report

Describing Progress Towards the Reasonable Progress Goals for Visibility in Class I Federal Areas

and Determination of Adequacy of Existing Implementation Plan to the Federal Land Managers

(FLMs) and the United States Environmental Protection Agency (US EPA) on January 4, 2013. The

WVDAQ requested that any request for an in-person consultation or teleconference, be made to the

agency within thirty days of receipt. No request for an in-person or teleconference was received. The

WVDAQ requested that comments be submitted by March 8, 2013. Comments were received from

Pat Brewer of the National Park Service, Jacqueline Lewis of US EPA, Region 3, and Sandra V.

Silva of the Fish and Wildlife Service.

I. United States Department of the Interior, National Park Service

COMMENT A:

As requested, I have reviewed West Virginia Department of Environmental Protection

(WVDEP)’s draft regional haze progress report. I believe that WVDEP has met the

requirements for the periodic progress report as outlined in 40 CFR 41.508 (g). I agree that

WVDEP has demonstrated that emissions reductions are on track to meet the 2018

reasonable progress goals established in the WV Regional Haze State Implementation Plan

(SIP) for Class I areas in WV. Further, WV emissions reductions are consistent with

assumptions used by neighboring states to set reasonable progress goals for their Class I

areas.

RESPONSE A:

No response required.

COMMENT B:

Section 1: Status of implementation measures: Since the majority of sulfur dioxide (SO2)

emissions reductions are due to electric generating units (EGU), it would make sense to

discuss EGU before other emission sectors.

Response to FLM Comments on Draft Regional Haze Progress Report Page - 1

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 23
RESPONSE B:

The discussion of EGUs was moved, so that it is the first measure discussed under Federal

Programs. The Progress Report was renumbered accordingly.

COMMENT C:

Section 1.2 covers Consent Decrees that were included in the VISTAS Best and Final

inventory and modeling run. It would be helpful to add reference at the end of that section

that consent decrees since 2008 are discussed under Reasonable Progress in Section 2.6.

RESPONSE C:

The following language has been added to Section C.1.2.: Consent Decrees that have been

executed since 2008, and therefore were not included in the initial RH SIP, are discussed

under Reasonable Progress in Section C.2.6.

COMMENT D:

Section 3: Figure 7 demonstrates that actual 2011 EGU emissions were below the projected

2018 EGU emissions included in VISTAS Best and Final modeling run. Table 10 compares

unit specific actual controls to controls assumed in VISTAS modeling. Table 11 addresses

EGUs specifically covered in the MANEVU Ask. Can you also summarize the emissions

reductions and facility shutdowns that would be applicable toward the MANEVU ask for

non-EGU SO2 emissions?

RESPONSE D:

A new section, Section 3.4.b MANE-VU “non-EGU Ask”, has been added which addresses

MANE-VU’s request for a 28% reduction in non-EGU SO2 emissions from 2002 levels.

Non-EGU sources have which have shutdown plants or units, or switched fuels have been

identified and the reductions quantified. A discussion of additional reductions from EGUs,

beyond those in the MANE-VU “EGU Ask” has also been added.

COMMENT E:

Section 5: Please provide additional background on the 2007 SEMAP inventory and its

objectives. The MANEVU draft SIP template provides a good description of the differences

between the Regional Planning Organization inventories and EPA’s National Emissions

Inventory (Mobile 6 vs MOVES models, state data vs Integrated Planning Model for EGU

growth and controls, NEI vs modeling inventory) that you might add/paraphrase in your

emissions inventory section.

Response to FLM Comments on Draft Regional Haze Progress Report Page - 2

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 24
RESPONSE E:

A discussion of the SEMAP inventory development and the differences between inventories

has been added to Section C.5.

COMMENT F:

Section 7: WV Contributions to Class I areas in neighboring states: your analysis identifies

WV non-EGU that contribute 0.5% to Class I areas in neighboring states. The analysis could

be strengthened by including the Area of Influence defined through the VISTAS process for

each Class I area and listing WV EGU and non-EGU in each AoI. How have emissions

changed for these sources?

RESPONSE F:

WV DAQ agrees that more detail is needed so a new section, Section B. Summary of the

Existing WV Regional Haze SIP, has been added that explains the development of the

original WV Regional Haze SIP and the decision to focus on sulfate as the dominate

contributor to regional haze, and EGU and non-EGU point sources as the dominate

contributor to sulfate. This section also explains the development of the Area of Influence

(AoI), and the selection of the 0.5% contribution threshold. As a result of the addition of this

section the document was renumbered accordingly.

WVDAQ agrees with the recommendation and has included additional maps, tables and

discussion for Brigantine, NJ; Great Smokey Mountains, NC and TN; James River Face,

VA; Linville Gorge, NC; Mammoth Cave, KY; and Shenandoah, VA. (See Section C.7).

Modifications were also made to the discussions in Section C.7 of the impact of West

Virginia sources on specific Class I areas identifies the non-EGU sources that impact a

specific Class I area. Only two West Virginia non-EGUs have an impact of greater than the

0.5% contribution threshold on any Class I area – WV Alloys and Capitol Cement. WV

Alloys impacts James River Face and Capitol Cement impacts Shenandoah. Both of these

sources are discussed earlier in the Progress Report and the reader is referred to the

appropriate sections [see Sections C.1.5 (Capitol Cement) and C.2.7 (Capitol Cement and

WV Alloys]. 

COMMENT G:

We appreciate the opportunity to work closely with WVDEP to improve visibility in our

Class I national park and wilderness areas.

RESPONSE G:

No response required.

Response to FLM Comments on Draft Regional Haze Progress Report Page - 3

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 25
II. United States Environmental Protection Agency

COMMENT A:

Section 1.1.c. Nonroad Diesel Emissions Program (40 CFR Part 89)

There is a typo in the 2nd paragraph, the word form should be from.

RESPONSE A:

WVDAQ agrees and has made the correction.

COMMENT B:

Section 1.6 Reasonable Progress Determinations

Please add the status of Capitol Cement Kilns 8 and 9 to this section. Table 3 of Section

1.5.a indicated that Kilns 7, 8 and 9 were shutdown in 2009.

RESPONSE B:

WVDAQ had added the statement: The modernization project was completed in 2009 and

Kilns 8 and 9 were replaced.

COMMENT C:

Section 2.1 Mercury Air Toxics Rule

There is a typo in the 2nd paragraph, last sentence the Federal Register Citation should be

77 FR 9304. There is also a typo in the 3rd paragraph, 1st sentence the letter “o” is missing

from the word power.

RESPONSE C:

WVDAQ agrees and has made the correction.

COMMENT D:

Section 2.6 Federal Consent Decrees

Please include the compliance dates for INVISTA and the shutdown date for the sulfuric acid

manufacturing unit at DuPont and Lucite International.

RESPONSE D:

WVDAQ had added the compliance dates.

Response to FLM Comments on Draft Regional Haze Progress Report Page - 4

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 26
COMMENT E:

Section 2.7 West Virginia Unit Specific Point Source Reductions

Table 6 lists Capitol Cement’s Kiln 7, should Kiln 8 be included in this table?

RESPONSE E:

Kiln 8 was replaced along with Kiln 9 as part of the modernization project at Capitol

Cement. Although Kiln 9 was subject to BART and Kiln 8 was not, the reductions from the

modernization project included the shutdown of Kiln 8. The modernization project was

accounted for in the original WV RH SIP, and Kiln 7 was permitted to remain for the

production of specialty colored cements. Kiln 7 is included in Table 6 because the reductions

from its shutdown were not accounted for in the original WV RH SIP. Since the reductions

from Kiln 8 have already been accounted for, Kiln 8 should not be included in Table 6. 

COMMENT F:

Section 3.1 EGU Reductions

Table 7 lists the facilities outside of West Virginia with a calculated visibility impact greater

than 0.5% on Dolly Sods, please add the state where the facilities are located.

There is a typo in the 1st paragraph under Figure 5, for consistence the letter “b” in Tbtu

should be capitalized.

RESPONSE F:

WVDAQ has added the requested information to the table, and made the suggested

correction.

COMMENT G:

Section 3.3 EGU Unit Specific Reductions

Please indicate the shutdown dates for units 7 and 8 at the Rivesville facility in Table 10.

RESPONSE G:

WVDAQ changed “Company announced shutdown by September 2012” to “Shutdown in

2012.”

Response to FLM Comments on Draft Regional Haze Progress Report Page - 5

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 27
COMMENT H:

Section 8 Assessment of Monitoring Strategies

There is a typo in the 1st paragraph above Figure 26, in the 1st sentence the letter “t” in the

word filter is missing.

RESPONSE H:

WVDAQ made the correction.

III. United States Department of the Interior, Fish and Wildlife Service

COMMENT:

On January 4,201 3, the State of West Virginia provided a draft 5-year progress report for

the State's Regional Haze State Implementation Plan (SIP). Although the U.S. Fish and

Wildlife Service (FWS) does not have Class I areas within West Virginia, the draft and

appendices include all of the necessary elements and information needed to adequately

address regional haze progress at our nearby Class I Refuges. The documents were

comprehensive and well written to accommodate a full review. We agree with the State's

conclusion of “negative declaration” and do not request further revision to West Virginia’s

Regional Haze SIP.

This letter acknowledges that the U.S. Department of Interior, FWS, has conducted a

substantive review of the draft Regional Haze SIP revision in fulfillment of the requirements

identified in 40 CFR 51.308(i). Please note that only the U.S. Environmental Protection

Agency (EPA) can make a final determination regarding the document's completeness and,

therefore, ability to receive federal approval from EPA.

It is noteworthy that West Virginia is one of the first States to submit a draft 5-year

progress report to the FWS for review. We compliment you on your hard work and

dedication to the significant improvement in our nation's air quality related values and

visibility.

RESPONSE:

No response required.

Response to FLM Comments on Draft Regional Haze Progress Report Page - 6

WV SIP Revision: Regional Haze 5-Year Periodic Report Page B - 28