Appendix N 

 Public Record 

Comments Received, and Responses, 

 Public Notice, and Hearing Report 

Tennessee Department of Environment and Conservation 

Division of Air Pollution Control 

9th Floor L&C Annex 

401 Church Street 

Nashville, TN 37243

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 1

April 4, 2008
Appendix N 

Public Record 

 Comments Received, and Responses, 

Public Notice, and Hearing Report 

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 2

April 4, 2008
Appendix N of Tennessee’s Regional Haze SIP summarizes the comments received regarding 

the preparation of the SIP and TDEC-APC’s response to them. 

Because of the importance of federal land manager (FLM) consultation in the development of 

this regional haze SIP, [See Section 169A of the Clean Air Act and 40 CFR 51.308(i)(2)&(3)] 

those discussions and comments appear first. 

Through the VISTAS RPO, Tennessee and the nine other member states worked extensively 

with the federal managers from the United States Department of the Interior and Department of 

Agriculture to develop the science that supports the regional haze SIPs for the VISTAS states. 

This process began in 2001 and continues to date. The discussions in this report focus on 

Tennessee’s interpretation of that science and the discussions with the FLMs regarding that 

interpretation and the preparation of the Tennessee regional haze SIP. 

The summary below pertains to the first public participation efforts of Tennessee for its regional 

haze SIP. That SIP was subjected to the opportunity for public participation and FLM 

discussions in the November to December 2007 time period. The comments received and verbal 

discussions with the FLMs and EPA are summarized below. To be conservative, Tennessee is 

taking its regional haze SIP out for a second round of public participation after modifying it to 

address the comments initially received. 

Generally, the FLMs appear supportive of Tennessee’s first regional haze SIP. Their comments 

are more toward additional detail to support Tennessee’s conclusions. Additionally, some of the 

FLM staff had difficulty in navigating through the CD of electronic support materials. 

Improvements have been made in this second SIP pre-hearing draft that should improve 

navigability. That includes tables of contents in the appendices and links from the narrative 

(when viewed in its electronic mode) to the appendices. 

1 Comments of the United States Department of the Interior FLMs 

The Department of the Interior houses both the FLMs from the National Park Service and the 

Fish & Wildlife Service. The FLMs from that federal department consolidated their comments 

regarding Tennessee’s SIP into a single document. Generally, their comments were as follows: 

2 BART 

Best Available Retrofit Technology (BART) should have more detail on the process by which 

sources were reviewed for being subject to BART. (EPA Region IV echoed this comment in 

their comments) In addition to the sources potentially subject to BART review process, there 

should be a TDEC-APC five factor analysis to accompany the final four BART source self 

analyses. 

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 3

April 4, 2008
In response to the above concerns, TDEC-APC has made significant additions to Section 7.5 of 

the SIP narrative and significant additions to Appendix L, the Appendix with details about 

BART. There is now more text about the review process to select potential BART sources for 

review, modeling protocols, modeled impacts, a discussion about the deciview exemption level 

in cases where BART sources may be clustered in proximity to one another and the agency’s 

impression and final findings regarding the BART sources that were unable to demonstrate 

exemption from BART due to modeled impacts. 

3 Long Term Strategy 

The source selection strategy for sources selected to be subject to the four-factor reasonable 

progress assessment following the VISTAS one percent or greater extinction threshold should be 

given more detail. A source-by-source listing in an area of influence for each Class I area in 

Tennessee This should also include sources that were exempted from BART. 

In response to these concerns, TDEC-APC added more text in the SIP narrative in Section 7.4 

and even more detail in Appendix H, the Appendix with supporting materials for reasonable 

progress analyses. TDEC-APC declares that it did not use a fixed cost per ton pass/fail value in 

assessing reasonable progress, but rather relied upon a multitude of factors that are detailed in the 

source-by source analysis of the narrative and in Appendix H. 

4 Additional NPS/FWS FLM Comments 

The FLMs recommended additional discussion in the narrative regarding Tennessee’s impact 

upon Class I areas outside of Tennessee and that has been done. Graphics and tabular 

information for Class I areas that Tennessee might impact are presented in the Appendices. The 

FLMs also had concerns about sources that were exempted under BART impact modeling, 

becoming a reasonable progress issue in future review cycles. Commitment language was added 

in Section 7.4 to state that TDEC-APC would monitor these sources for their cumulative impacts 

in future review cycles leading up to the 2064 deadline to reach natural conditions. 

The FLMs also wanted additional information presented regarding interstate consultations with 

neighboring states with emissions that might be impacting Tennessee’s Class I areas. Additional 

text is provided in Section 10 and copies of correspondence with neighboring states regarding 

their impacts upon Tennessee Class I areas and Tennessee’s impacts upon their Class I areas are 

provided in Appendix J. 

Prescribed fire is discussed in all of the comments. Tennessee has a statutory exemption on 

woodwaste burning at Tennessee Code Annotated Section 68-201-115(c) that limits what TDECAPC is able to mandate in terms of regulating prescribed burning in forestry management. 

TDEC-APC will work with stakeholders to develop smoke management plans, but cannot 

guarantee the enforceability of these plans. 

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 4

April 4, 2008
5 Comments of the United States Department of Agriculture FLM 

The Department of Agriculture houses both the FLMs from the Forest Service. Generally, their 

comments were as follows: 

The FLM requested a before and after Tennessee coal-fired power plant by power plant emission 

profiles in response to the Clean Air Interstate Rule (CAIR). That information has been 

incorporated into the SIP narrative under Section 7.2.1 under the CAIR discussion. 

The FLM observed that the graphic for 20 % best days at Joyce Kilmer was missing at Figure 

7.2.4-4. As the IMPROVE monitor at Great Smoky Mountains National Park represents both 

GSMNP & JOKI, TDEC-APC placed a notation that GSMNP’s graphic also represented JOKI’s 

graphic. 

Like the DOI FLM, the Forest Service FLM wanted additional text about the impact of 

Tennessee sources upon other Class I areas. Per the previous discussion under the DOI FLM 

concerns, TDEC-APC believes that it has addressed these concerns in the second pre-hearing 

draft of its regional haze SIP. 

The Forest Service FLM agreed with TDEC-APC that wildland fires were not a significant 

contributor though SEVIC commented that it felt the importance of wildfire had been discounted 

in the analysis. The Forest Service FLM commented that it felt making a Smoke Management 

Plan for prescribed burning a part of the SIP would be too cumbersome to make any minor 

needed changes in such a dynamic document. 

6 Comments of the United States Environmental Protection Agency 

While the concerns of the FLMs are very important in the review of the regional haze SIP, the 

final authority for approving or disapproving of Tennessee’s regional haze SIP rests with 

USEPA. Accordingly, a discussion of their comments appears next in this report of comments 

received. 

EPA wanted to make certain that any discussions of control measures or future actions was 

delineated between enforceable commitment and aspirational goals and the narrative has been 

revised to make that delineation clear. 

As previously discussed under the FLM comments, USEPA wanted to know more about how 

Tennessee made its determination of which sources were BART eligible and those that finally 

ended up having to do BART. For the sources that did have to apply BART, USEPA wanted to 

know more about Tennessee’s rationale in making its decisions and the specificity of what 

constituted BART for these sources. Language has been added to the SIP narrative to describe 

that process. EPA also had difficulty in managing the review of the documents in the initial prehearing draft like some of the FLMs and as previously mentioned, electronic links, page numbers 

and tables of contents for the appendices have been added to improve the navigability of the SIP 

for reviewers. 

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 5

April 4, 2008
USEPA also had concerns about the use of websites in a SIP due to the temporal nature of sites. 

TDEC-APC has removed such references except as authorized in Appendix I that refers to 

additional background information. 

In the narrative itself, USEPA recommended that additional text be included as to how natural 

background conditions were determined. TDEC-APC has added some text to the narrative, but 

continues to primarily rely upon the regionally developed VISTAS science package that was 

funded and overseen in its development as an adequate demonstration of the validity of the 

science and the interpretation of that science. Again, the FLMs participated in the process of 

developing natural condition values throughout the process and seem satisfied that the values 

selected for the Tennessee Class I areas are proper. The abundance of information in Appendix 

B is evidence that much thought, study and analysis have gone into the determination of these 

values. 

Like the FLMs, USEPA wanted to know more about the long-term strategy portion of 

Tennessee’s regional haze SIP for reasonable progress control and area of impact analyses. As 

discussed previously, additional information has been provided in the second pre-hearing draft 

that should address those concerns. 

USEPA also wanted to know more about model performance analysis and that has been provided 

in the second pre-hearing draft. That information is also provided in the second pre-hearing 

draft. 

7 Source Comments 

Comments from sources came from: 

• Eastman Chemical Company in Kingsport, Tennessee, an industrial BART source 

making an expenditure of approximately $200 million to control its sulfur dioxide 

emissions 

• Bowater Newsprint in Calhoun, Tennessee, an industrial source evaluated under a 

reasonable progress analysis, and 

• SEVIC (Southeastern Visibility Industrial Coalition) a group of non-EGU sources 

monitoring the work of the southeastern states in developing their regional haze SIPs and 

the work done in the VISTAS process. 

Eastman’s comments were specific to the BART limits proposed for it in the narrative of the first 

pre-hearing draft. Among other things, Eastman desired the flexibility to change control 

technology from spray dryer absorbers to wet flue gas desulfurization if that technology later 

proved to be better. TDEC-APC believes that it has resolved the concerns of Eastman, the FLMs 

and USEPA by replacing the former text with a stand-alone Title V permit condition. The 

condition specifies the timing and degree of pollutant reductions and also specifies compliance 

assurance monitoring, reporting and recordkeeping procedures. This condition has been 

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 6

April 4, 2008
reviewed by Eastman and will become a source-specific SIP revision to meet the requirements of 

the regional haze SIP process. It will then become an “applicable requirement” as that term is 

described under 40 CFR 70 for incorporation into the facility’s Title V (part 70) operating 

permit. 

Eastman also declared that as a member of SEVIC, it supported their comments. Those will be 

addressed below. 

Bowater Newsprint filed comments recommending that TDEC-APC’s proposal to address 

visibility impairment from new sources be limited to strictly what is in the PSD rules, or conduct 

rulemaking independent of the regional haze SIP. It also recommended that the language in the 

first pre-hearing draft that mentioned the possibility of additional control at Bowater might be 

required for reasons other than this first review of the regional haze SIP should be deleted. 

TDEC-APC has made revisions in the second pre-hearing draft that it believes will be 

satisfactory to Bowater. 

SEVIC, like EPA and the FLMs wanted more documentation of TDEC-APC’s rationale in the 

hearing record to help defend any challenges. As previously mentioned, TDEC-APC believes it 

has provided that specificity in the second pre-hearing draft. 

Also mentioned previously was SEVIC’s belief that TDEC-APC had discounted the role of 

smoke from wildland fires from its initial analysis of visibility impairing pollutants. SEVIC 

made similar comments on the North Carolina regional haze SIP (recall that Tennessee shares 

two Class I areas, Great Smoky Mountains National Park and Joyce Kilmer Wilderness Area 

with North Carolina). Tennessee consulted with VISTAS technical staff to confirm its original 

statements that sulfate was the primary reason for visibility impairment in these two Class I areas 

and that organic carbon from fire played very little in that role. As such, the finding remains the 

same for this first planning period. 

In like fashion, SEVIC was also concerned over TDEC-APC’s declaration that dust control 

measures would not be made a part of the Tennessee regional haze SIP. Chapter 1200-3-8 is 

already a part of the Tennessee SIP for meeting particulate matter national ambient air quality 

standards. Until evidence demonstrates that fugitive dust also impairs the timely attainment of 

the regional haze natural background goals, TDEC-APC will not make it a part of the regional 

haze SIP. 

The following EPA comments were received in the second round of public participation. TDEC-APC

responses to the comments are addressed in detail following the comments and prior to having the 

Tennessee Air Pollution Control Board act upon the approval of the regional haze SIP for submission to 

USEPA. 

 

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 7

April 4, 2008
Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 8

April 4, 2008
Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 9

April 4, 2008
Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 10

April 4, 2008
Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 11

April 4, 2008
Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 12

April 4, 2008
Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 13

April 4, 2008
March 25, 2008 - Public Hearing Comment Summary And Agency Respons

Commenter Comment TDEC-APC Response 

USEPA: 

SIP 

Narrative 

Comment 

#1 

Executive Summary, Page iii: Add language to discuss the 4 BART sources that will be controlled and add an affirmative declaration that BART eligible sources exempted from control were found to not cause visibility problems at any Class I areas. 

The agency agrees with this comment and hthe Executive Summary to address this com

USEPA: 

SIP 

Narrative 

Comment 

#2a 

Page 10: Section 2.3 of the Narrative refers the reader to Appendix B for more information on how the new IMPROVE equation was used to estimate natural background conditions, yet there is no information to that effect in Appendix B. 

The information is already provided in attachments: Appendix B-2 - Revised IMPROVE algorithm Appendix B-4 – Natural Background & VisibAppendix G – Modeling Results & Supple(for GRSM) 

USEPA: 

SIP 

Narrative 

Comment 

#2b 

Page 10: A citation is needed in either section 2.1 or 2.3 that leads the reader to the location in the SIP where the identity of the 20 percent best and worst days for Tennessee Class I areas is declared. 

The citation to Appendix F-2 has been addedeclaring the location of the 20 percent besfor Tennessee Class I areas. 

USEPA: 

SIP 

Narrative 

Comment 

#3 

Section 1.5, Page 6: Either reference the procedures for future, continuing consultation with the FLMs per 40 CFR 51.308(i) to Section 11, or describe them in more detail in Section 1.5 

A reference to Section 11 and additional texconsultation has been added to Section 1.5 

USEPA: 

SIP 

Narrative 

Comment 

#4 

Page 15, Figures 3.1-1 and 3.1-2 and similar figures in Section 7.2.4 reference a “Method 1 Prediction”, yet there is no explanation of what that means in the narrative. 

An explanation of “Method 1 Prediction” hathe figures and section mentioned in this EPMethod 1 Prediction means using EPA defaestimating Natural Conditions at Class I arin Appendix B-4 (page 31). 

Comments Received, Resposes, and Public HearingRegional Haze SIP for TN Class I areas
Commenter Comment TDEC-APC Response 

USEPA: 

SIP 

Narrative 

Comment 

#5 

Data Tables 7.2.3-1 and 7.2.3-2 do not match the data in Tables 5 and 6 respectively of Appendix D.3 

The data have been updated to Base G4 (Bto match the Narrative and Appendix D.3 

USEPA: 

SIP 

Narrative 

Comment 

#6 

Section 7.5.3 pp 55-59: More explanation needs to be provided on how Tennessee will establish enforceable BART limits upon affected sources – Discuss the role of Tennessee Chapter 1200-3-23 in applying these limits to sources. 

Chapter 1200-3-23 clearly authorizes protection requirements to be imposed upopermit term. [See Rule 1200-3-23-.05]. The BART sources are also Part 70 sources. Thadding BART limits established under the reto the permit as an “applicable requirementdefined under Part 70 are federal rules that follow. The SIP narrative contains BART source that, upon approval by EPA, wincorporated into the source’s Part 70 permiIn summary, Tennessee has the authority to as a permit term under its Rule 1200-3-23-.to add it into the BART source’s federally 70 permit as a new applicable requiremenapproved Tennessee Rule 1200-3-9-.02permits that set these BART limits in the iare incorporated into the Part 70 permits apL-12. 

USEPA: 

SIP 

Narrative 

Comment 

#6a 

Section 7.5.2: The BART de-listing of Weyerhaeuser in Sullivan County needs additional discussion/justification. 

Text justifying the delisting of Weyerhaeusource has been added to Section 7.5.2. 

Comments Received, Resposes, and Public HearingRegional Haze SIP for TN Class I areas
Commenter Comment TDEC-APC Response 

USEPA: 

SIP 

Narrative 

Comment 

#6b 

Section 7.5.2 p. 52 - Holston Army Ammunition Plant’s exemption from BART through permit limitations: A permit term is needed to declare that any subsequent increase in emissions at this facility above the BART emissions threshold will trigger BART. 

Construction Permit # 961638P was issued February 25, 2008 limiting the facility’s pvisibility impairing pollutants below the BTDEC understands the context of the commto insert such language in the facility’s opethe extent that it is allowed in federal and sta

USEPA: 

SIP 

Narrative 

Comment 

#7 

Page 52: TDEC declared that it did not evaluate emissions of VOC an ammonia for BART. That conflicts with statements made in Section 6.2 of Appendix L (page L-15). The two statements should be reconciled. 

The SIP Narrative and Appendix L have bereflect harmony in statements relative to VOwith respect to BART. 

USEPA: 

SIP 

Narrative 

Comment 

#8 

Section 7.8, Step 3, Page 69; Appendix H, Step 23, page H-54: An evaluation of the four reasonable progress factors must accompany the State’s justification that the CAIR is sufficient for reasonable progress for subject electric generating units during the first planning period. 

Additional text has been provided in the SAppendix H similar to the language employeNorth Carolina. 

USEPA: 

SIP 

Narrative 

Comment 

#9 

Section 7.8, Step 4, page 69: A brief summary of the rationale to support the one percent threshold choice or a reference to Section 5.0 of Appendix H should be provided in the SIP narrative. 

A reference to Section 5.0 of Appendix H hain the SIP narrative. 

USEPA: 

SIP 

Narrative 

Comment # 

10a 

Identifying sources for reasonable progress control – Step 4, page 69: Additional justification/explanation of how the use of incorrect SO2 Emissions at Tate & Lyle (formerly A. E. Staley) justified exempting the facility from the 4-factor analysis. 

Additional justification/explanation for Tate added to the SIP narrative in this section. 

Comments Received, Resposes, and Public HearingRegional Haze SIP for TN Class I areas
Commenter Comment TDEC-APC Response 

USEPA: 

SIP 

Narrative 

Comment 

#10b 

Identifying sources for reasonable progress control – Step 4, page 69: Additional information/ justification is needed for APACTN Harrison Construction relative to the emissions mischaracterization and why the emission unit is no longer considered significant. 

Additional justification/explanation for Construction has been added to the SIP section. 

USEPA: 

SIP 

Narrative 

Comment 

#10c 

Identifying sources for reasonable progress control – Step 4, page 69: Additional information/ justification is needed for the DOE Y-12 Plant relative to the emissions reduction project and why the facility is no longer considered significant 

Additional justification/explanation for the repowering project has been added to the this section and also in appendix H narrative

USEPA: 

SIP 

Narrative 

Comment 

#10(d) 

Section 10, page 75: Tennessee should clarify what it is planning to do to address MANE-VU’s request for non EGU emissions reductions 

Clarifying language has been added to the explain Tennessee’s response to MANadditional non EGU emission reductions. 

USEPA: 

SIP 

Narrative 

Comment # 

11 

Section 13, page 78: The state may wish to clarify that no non-BART sources were documented to impact other states’ Class I areas. 

The requested language has been added tthe SIP narrative addressing non-BART sources. Additionally, non BART TN soClass I areas outside of TN at 1% contribualso addressed in Table 13.2 main SIP narra

USEPA: 

SIP 

Narrative 

Comment 

#12 

Appendix D.6b: How will the sources listed as shut down in this section result in enforceable emission reductions? 

Clarifying language has been added to Appendix D. 

USEPA: 

Appendix H 

Comment a. 

General: Tennessee should declare whether or not it agreed with INVISTA and Bowater’s 4 factor analysis – noting any areas of disagreement 

Clarifying language has been added to Appendix H Narrative. 

Comments Received, Resposes, and Public HearingRegional Haze SIP for TN Class I areas
Commenter Comment TDEC-APC Response 

USEPA: 

Appendix H 

Comment b. 

Page H-57: Consider listing cost effectiveness for Bowater to switch to lower sulfur (0.6%) coal 

Clarifying language has been added to Appendix H Narrative. 

USEPA 

Appendix H 

Comment c 

Page H-57: A state or federally enforceable operating permit should be imposed upon Bowater to limit the remaining useful life of the boilers if it was a deciding factor in Tennessee’s decision to not require reasonable progress controls during this review period. 

Clarifying language has been added to Appendix H Narrative. 

USEPA 

Appendix H Comment d 

Page H-61:Tennessee should justify why INVISTA was not required to use a lower sulfur coal at the $1,225 per ton of SO2 removed level. 

Clarifying language has been added to Appendix H Narrative. 

USEPA: 

Appendix I 

Comment a. 

This Appendix does not discuss how the BART modeling files will be archived, maintained and made available by the State to EPA and the public. 

Clarifying language has been added to Appendix I. Appendix I header, page 2. 

USEPA: 

Appendix L 

Comment a. 

Revised titles for the tables in Appendices L2, L-3, and L-10 are recommended that clarifies what the emission data represents with respect to BART eligibility or other aspects of the BART program. 

Revised Titles were addressed for AppendicL.-10. 

Comments Received, Resposes, and Public HearingRegional Haze SIP for TN Class I areas
Commenter Comment TDEC-APC Response 

USEPA: 

Appendix L 

Comment b. 

Section 4, p. L-10 : This section contains the discussion regarding how the 0.5 deciview BART contribution threshold was chosen. The discussion contains many good references to the BART guidelines and provides a useful map of BART sources in the VISTAS region. The last paragraph of this section presents TDEC-APC’s conclusion that the 0.5 dv threshold is appropriate because there are a limited number of out-of-state sources that impact the TN Class I Areas. This rationale should be expanded to address the spatial location of BART sources both in TN and outside the State. Looking at Figure 4-1, there do not appear to be any large clusters of sources, which would be expected to have a large combined impact at a Class I area on any given day. A discussion of this nature would enhance the conclusion of selecting the 0.5 dv threshold. A reference to the effect of clusters of sources is included in Section 7.5.2 of the SIP Narrative, but it would be helpful to provide a more detailed discussion of this issue in Appendix L. 

Clarifying language has been added to Appendix L Narrative. 

Comments Received, Resposes, and Public HearingRegional Haze SIP for TN Class I areas
Commenter Comment TDEC-APC Response 

USEPA: 

Appendix L 

Comment c. 

Section 7.3, p. L-26 : The State may want to update the table numbering described in the narrative for clarity. We believe narrative references to Tables 5-3 and 5-4 are meant to read 7-7 and 7-8. Similarly, on page L-29, it appears that Table 7-8 in the narrative followed by a Table numbered as 7-7 could be updated in both places as 7-9. 

Mentioned Tables were correctly numbered. 

USEPA: 

Appendix L 

Comment d. 

There are a number of areas in Appendix L which are incomplete. The areas are highlighted in yellow. It is assumed that these sections will be completed with the appropriate information prior to the Final SIP being submitted to EPA. 

Appendix L highlights were removed and refattachments were properly addressed. 

Comments Received, Resposes, and Public HearingRegional Haze SIP for TN Class I areas
This section is reserved for the Public Notice and Public Hearing Report. 

NOTICE 

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 Pollution 

Control Board to consider the proposed Fine Particulate Matter (PM2.5) State Implementation 

Plan (SIP and 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 9:30 a.m. on March 25, 2008. 

Written comments will be included in the hearing records if received by the close of business (4:30 PM CDT) March 

25, 2008, at the office of the Technical Secretary, Tennessee Air Pollution Control Board, 9th Floor, L & C Annex, 

401 Church Street, Nashville, TN 37243-1531. 

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 March 25, 2008, 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, 12th 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 PM2.5 SIP, you may contact Mr. Travis Blake at 

(615) 532-0617. 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, 9th Floor, L & C Annex, 401 Church Street, Nashville, TN 37243-1531, telephone (615) 

532-0600. 

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 21

April 4, 2008
Summary of Proposed Change 

The fine particulate matter (PM2.5) SIP for the Knoxville PM2.5 non-attainment area and the Regional Haze SIP 

will be discussed in a public hearing March 25, 2008, at 9:30 a.m. in the 9th Floor Conference Room of the L & C 

Annex, located at 401 Church Street, Nashville, Tennessee 37243-1531. Copies of the SIP are now in the public 

depositories for public inspection. 

The U. S. Environmental Protection Agency (EPA) designated Anderson, Blount, Knox, and Loudon Counties, and 

the portion of Roane County that includes the Tennessee Valley Authority’s Kingston Fossil Plant, as nonattainment for the annual PM2.5 National Ambient Air Quality Standard (NAAQS), effective April 5, 2005. EPA’s 

finding was based upon air quality monitoring data at several sites within this region between 2001 and 2003. As a 

result of this designation, Tennessee is required to submit a State Implementation Plan (SIP) to EPA by April 5, 

2008, that demonstrates progress toward attainment. Tennessee proposes to demonstrate in the SIP that the 

Knoxville area will attain the PM2.5 NAAQS in 2009, based on air quality modeling results, emissions inventories, 

and other evidence. 

Air quality modeling conducted for Tennessee by the Association for Southeastern Integrated Planning (ASIP) 

indicates that the Knoxville-area non-attainment counties will attain the NAAQS in 2009. The model results are 

based upon 2002-2009 emissions reductions from Knoxville area sources and are supported by downward trends in 

emissions, with concurrent improvements in air quality for the Knoxville area. Tennessee expects to attain the 

PM2.5 NAAQS in the Knoxville region based upon implementation of Federal measures, and no additional local 

controls are planned.

EPA’s PM2.5 Implementation Rule requires States to address nitrogen oxides (NOX) as a PM2.5 attainment plan 

precursor and evaluate sources of NOX emissions in the State for control measures, unless the State and EPA provide 

an appropriate technical demonstration for a specific area showing that NOX emissions from sources in the State do 

not significantly contribute to PM2.5 concentrations in the non-attainment area. Tennessee is submitting two options 

to address NOX as a PM2.5 attainment plan precursor, as follows: 

1. The draft SIP contains a technical demonstration, which shows that NOX emissions from sources in the State do 

not significantly contribute to PM2.5 non-attainment in the Knoxville area. Tennessee proposes to submit this 

technical demonstration to U. S. EPA for approval as part of the PM2.5 attainment demonstration. If EPA 

approves this demonstration, then Tennessee proposes to take no further action to address NOX as a PM2.5 

attainment plan precursor. A copy of the insignificance determination is included in the public depository with 

the draft SIP. 

2. If EPA disapproves Tennessee’s technical demonstration for NOX, or if Tennessee otherwise determines that the 

State must address NOX as a PM2.5 attainment plan precursor, then Tennessee proposes to submit an addendum 

to the PM2.5 SIP, which includes emission inventory data, control measures, motor vehicle emissions budgets, 

RACT/RACM, and contingency plan measures to address NOX. The information contained in this addendum 

would become a Federally enforceable part of the SIP. If EPA approves Tennessee’s technical demonstration 

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 22

April 4, 2008
for NOX, or if Tennessee otherwise determines that the State is not required to address NOX as a PM2.5 

attainment plan precursor, then Tennessee would take no further information on the addendum. A copy of the 

draft SIP addendum for NOX is included in the public depository with the draft SIP. 

Tennessee specifically solicits comments on both proposed approaches outlined above, and upon the appropriateness 

of including or excluding NOX as a PM2.5 attainment plan precursor. 

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 second public hearing for Tennessee’s Regional Haze SIP. Numerous changes 

have been made to the original draft SIP, and the Division has elected to provide a second 

opportunity for public comment because of these changes. The Regional Haze SIPs for the first 

review period were due December 17, 2007. These plans will cover long-term strategies for 

visibility improvement between baseline conditions in 2002 and 2018. States are required to 

evaluate progress every five years to assure that emission controls are on track with emissions 

reduction forecasts in each SIP. At both Class I areas in Tennessee, visibility improvements on 

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

based solely on reductions from existing and planned emissions controls. 

Revisions 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 February 22, 2008, at the following locations: 

H

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 23

April 4, 2008
Air Pollution Control Division Chattanooga – Hamilton County Air Pollution Control Division

9th Floor, L & C Annex Air Pollution Control Bureau Cookeville EFO 

401 Church Street 6125 Preservation Drive 1221 South Willow Ave. 

Nashville, TN 37243 Chattanooga, TN 37416 Cookeville, TN 38506 

Air Pollution Control Division Air Pollution Control Division Air Pollution Control Division 

Knoxville EFO Johnson City EFO Jackson EFO 

3711 Middlebrook Pk 2305 Silverdale Road 362 Carriage House Drive 

Knoxville, TN 37921 Johnson City, TN 37601 - 2162 Jackson, TN 38305 - 2222 

Air Pollution Control Division Knox County Department of Division Air Pollution Control 

Columbia EFO Air Pollution Control Memphis - Shelby Co. Health Dept. 

2484 Park Plus Drive 140 Dameron Avenue 814 Jefferson Avenue 

Columbia, TN 38401 Knoxville, TN 37917-6413 Memphis, TN 38105 

Air Pollution Control Division Pollution Control Division U.S. EPA, Region IV 

Chattanooga EFO Metropolitan Health Department APTMD - 12th Floor 

Suite 550 311 23rd Ave. North Atlanta Federal Center 

540 McCallie Ave. Nashville, TN 37203 61 Forsyth Street S.W. 

Chattanooga, TN 37402 - 2013 Atlanta, Georgia 30303 

 c/o Mr. Dick Schutt, Chief 

Air Pollution Control Division Kingsport Public Library 

Nashville EFO 400 Broad Street 

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 24

April 4, 2008
711 R. S. Gass Blvd. Kingsport, TN 37660 

Nashville, TN 37243 

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 proposed PM2.5 SIP and also 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 March 25, 2008, at the 

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

Nashville, Tennessee, 37243-1531. 

D:/ln/MAR2008.doc 

Comments Received, Resposes, and Public Hearing

Regional Haze SIP for TN Class I areas

Appendix N.7 - 25

April 4, 2008