west virginia department of environmental protection



# Appendix B: Interagency Consultation

Promoting a healthy environment.[This page intentionally left blank.]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 Y ear 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[This page intentionally left blank.]

# 60-Day Consultation Communications[This page intentionally left blank.]Division of Air Quality

601 57 th 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 in tent that by 2064 the visibility in all Class I areas
will be returned to natural cond itions. The RHR also requires the St ate to consult with the Federal Land Management agencies at least 60 days pr ior to holding any public hearing on a RHR SIP or SIP revision (40CFR51.308(i)). We be lieve 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 Protec tion Agency (EPA) on June 18, 2008. On March 23, 2012, the EPA published a final rule granting lim ited approval (77FR16937) of West Virginia’s Regional Haze SIP. EPA identified a general deficien cy 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 impl emented and continue operating. It should be noted



### Promoting a healthy environment.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 Ba llou (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) requi res States to develop State Impl ementation Plans (SIPs) to reduce visibility impairment with the expre ss intent that by 2064 the visibility in all Class I areas wi ll be returned to
natural conditions. The RHR al so requires the State to consult with th e Federal Land Management agencies a t 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 suffi ciently accomplished via phone or writt en communication, including email and/or letter. However, if your agency desires an in-per son consultation or teleconfer ence, 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 Protec tion (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 Re gional Haze SIP. EPA identified a general deficiency related to the federal Clean Air Interstate Rule for most, if not all, states in the eastern Unite d States, even though most controls in West Virginia were required by mechanisms other than CAIR. As

su b sequent litigation has unfolded, EPA has acknowledged that CAIR is still in place and will be for the nea r 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 cap acity in the State is controlled by Flue Gas Desulfurization (FGD) to significantly reduc e 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 evalua ting 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 Vi rginia’s required 60-da y consultation period.

Today DEP is sending, via express courie r, packages to each FLM office that include the draft SIP with full electronic supporting documentation. Please acknowledge th e 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 quest ions 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,2 Fred Durham

# Comments[This page intentionally left blank.]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 Regi onal 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 2 nd 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 2 nd paragraph, last sentence the Federal Regist er citation should be 77 FR 9304. There is also a typo in the 3 rd paragraph, 1 st sentence the letter “o” is mi ssing from the word power.

Section 2.6 Federal Consent Decrees

Please include the compliance date for INVISTA and the sh utdown 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, shoul d Kiln 8 be included in this table?

Section 3.1 EGU Reductions

Table 7 list the facilities out side of West Virginia with a calculated visibility imp act greater than 0.5% on Dolly Sods, please add the state wher e the facilities are located.

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

Section 3.3 EGU Unit Specific Reductions

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

Section 8 Assessment of Monitoring Strategies2 There is a typo in the 1 st paragraph above Figure 26, in the 1 st 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. Thompso n" <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.virgin ia.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 Mana ger (FLM) Partners:

The 1999 Regional Haze Rule (RHR) requi res States to develop State Implementation Plans (SIPs) to reduce visibility impairment with the express intent that by 2064 th e visibility in all Class I areas will be returned to
natural conditions. The RHR al so requires the State to c onsult 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 accomplishe d via phone or written co mmunication, including email and/or letter. However, if your agency desires an in-per son consultation or teleconfer ence, 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) submitte d 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 Re gional 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 th at CAIR is still in place and will be for the near future. In any event, most of the c ontrols 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 vi sibility impairment in the sout heast, including West Virginia.

The RHR at 40 CFR 51.308(g) requires periodic reports evaluating progre ss 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 Wilderness3 Areas. Please assist the DEP in starting West Virginia’s requir ed 60-day consultation period.

Today DEP is sending, via express courie r, packages to each FLM office th at include the draft SIP with full electronic supporting document ation. Please acknowledge the date of said package receipt as the formal commencement of the required 60-day re view period. We would appreciate your formal comments on or before March 8, 2013. Should you have any ques tions 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][This page intentionally left blank.]TRANSMITTED VIA ELECTRONIC MAIL

- NO HARDCOPY TO FOLLOW

N3615 (2350)

March 6, 2013

Memorandum

To: L aura 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 W est Virginia D epartment of Environmental Protecti on (WVDEP) ’ s draft regional haze progress report

. I believe that WVDEP ha s 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 assumption s used by neighboring states to set reasonable pro gress goals for their Class I areas

.

I have a few suggestions for you to consider to streng then the report

.

Section 1: Status of implementation measures: Since the majority of sulfur dioxide (SO 2 )
emissions reductions are due to electric generating units ( EGU )

, it would make sense to discuss
EGU before other emission sectors.

S ection 1.2 cover s 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 we re below the projected
2018 EGU emissions included in VISTAS Best and Final modeling run. Table 10 compare s unit specific actual controls to controls assumed in VISTAS modeling

. Table 11 addresses EGU s specifically covered in the MANEVU Ask. Can you also summarize the emissions reductions and facility shutdown s that would be appli cable toward the MANEVU ask for non

- EGU S O 2 emissions? 

# United States Department of the Interior

NATIONAL PARK SERVICE
Air Resources Division
P.O. Box 25287 Denver, CO 80225

- 02872

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

. The MANEVU draft SIP template provides a good description of the differences
between the R egional Planning Organization inventories and EPA ’ s National Emissions
I nventor y ( Mobile 6 vs MOVES models , state data vs I ntegrated Planning Mo del 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. T he 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 source s?

We appreciate the opportunity to work closely with WVDEP to improve visibility in our Class I national park and wilderness areas.INREPLYREFERTO;FWSiANWS-AR-AQUnitedStatesDepartmentoftheInteriorFISHANDWILDLIFESERVICENationalWildlifeRefugeSystemBranchofAirQuality7333W.JeffersonAve.,Suite375Lakewood,CO80235-2017March8,2013**viae-mail transmission-hardcopywillnotfollow* *Mr.William Fredrick DurhamDeputyDirector-AirQualityWestVirginia Department of Environmental Protection60157thStreetSECharleston. West Virginia 25304Dear Mr.Durham:OnJanuary4,2013,theStateofWest Virginia provideda draft5-year progress report for theState's Regional HazeStateImplementation Plan (SIP). AlthoughtheU.S. Fish and WildlifeService (FWS) does not have ClassIareas withinWestVirginia,thedraft and appendicesinclude all ofthenecessary elements and information neededtoadequately address regionalhazeprogressat ournearbyClass IRefuges. The documents were comprehensive and well writtentoaccommodateafull review. We agree with the State's conclusion of "negative declaration"anddonotrequest further revisiontoWest Virginia's Regional Haze SIP.This letter acknowledges thattheU.S. DepartmentofInterior,FWS,has conductedasubstantivereview of the draft Regional Haze SIP revisioninfulfillmentoftherequirements identifiedin40CFR 51.308(i).Pleasenotethatonlythe U.S. Environmental Protection Agency (EPA) canmakeafinaldeterminationregarding the document's completeness and, therefore, ability toreceive federal approvalfrom EPA.Itis noteworthy that West Virginiaisoneof the first States to submitadraft 5-year progressreporttothe FWS forreview.We compliment you on your hard work and dedication to thesignificant improvement inournation'sairquality related values and visibility.Sincerely,dandraV. SilvaChief, Branch of Air Qualityw[This page intentionally left blank.]

# Response to Comments[This page intentionally left blank.]

### 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 Environmenta l 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 Pr otection 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 Virgin ia Department of Envi ronmental 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 ge nerating units (EGU), it would make sense to discuss EGU before other emission sectors.

Response to FLM Comments on Draft Regional Haze Progress Report Page - 1RESPONSE 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 incl uded 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 su mmarize 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 M ANE-VU “non-EGU Ask”, has been added which addresses MANE-VU’s request for a 28% reduction in non-EGU SO 2 emissions from 2002 levels. Non-EGU sources have which have shutdown pl ants or units, or switched fuels have been identified and the reductions quantified. A disc ussion 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 pr ovides a good description of the differences between the Regional Planning Organization inventories and EPA’s National Emissions Inventory (Mobile 6 vs MOVES models, stat e 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 - 2RESPONSE E:

A discussion of the SEMAP inventory developm ent and the differences between inventories
has been added to Section C.5.

COMMENT F:

Section 7: WV Contributions to Class I area s in neighboring states: your analysis identifies
WV non-EGU that contribute 0.5% to Class I areas in neighbori ng states. The analysis could be strengthened by including the Area of In fluence 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 deci sion to focus on sulfate as the dominate contributor to regional haze, and EGU a nd non-EGU point sources as the dominate contributor to sulfate. This section also expl ains the development of the Area of Influence (AoI), and the selection of the 0.5% contributi on 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 Smoke y 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 discu ssions in Section C.7 of the impact of West Virginia sources on specific Class I areas id entifies 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 - 3II. 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 2 nd 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 Kiln s 8 and 9 to this secti on. 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 moderni zation 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 2 nd paragraph, last sentence the Federal Register Citation should be 77 FR 9304. There is also a typo in the 3 rd paragraph, 1 st 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 INVI STA 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 - 4COMMENT 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 th e 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 Virgin ia 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 1 st 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 shutdow n by September 2012” to “Shutdown in
2012.”

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

Section 8 Assessment of Monitoring Strategies There is a typo in the 1 st paragraph above Figure 26, in the 1 st 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 Implemen tation 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 elem ents 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 determinati on 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