# Appendix N

Public Record

Comments Received

, and Responses, Public Notice, and Hearing Report

Tennessee Department of Environment and Conservation

Division of Air Pollution Control

9 th 

### Floor L&C Annex

401 Church Street Nashville, TN 37243

# Appendix N

Public Record

Comments Received, and Responses,

Public Notice, and Hearing Report

### Appendix N of Tennessee’s Regional Haze SIP summ arizes 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 scienc e 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 th e first public participation effo rts 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 summarize d 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 Tenn essee’s conclusions. Additionally, some of the FLM staff had difficulty in navi gating through the CD of elec tronic 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 th e FLMs from the National Park Service and the

Fish & Wildlife Service. The FLMs from that fe deral 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) sh ould 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 poten tially subject to BART review process, there should be a TDEC-APC five factor analysis to accompany the final four BART source self analyses.

### In response to the above concer ns, 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 se lect 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 re garding 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 extincti on threshold should be given more detail. A source-by-s ource listing in an area of infl uence for each Class I area in

Tennessee This should also include sour ces 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 Ap pendix with supporting ma terials for reasonable progress analyses. TDEC-APC decl ares 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 th at has been done. Gr aphics 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 re view cycles. Commitment language was added

in Section 7.4 to state that TD EC-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 pres ented regarding intersta te consultations with neighboring states with emissions that might be impacting Tenness ee’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 Te nnessee’s impacts upon their Class I areas are provided in Appendix J.

Prescribed fire is discussed in all of the co mments. 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 st akeholders to develop smoke management plans, but cannot guarantee the enforceability of these plans.

## 5 Comments of the United States Department of Agriculture FLM

The Department of Agriculture houses both the FLMs from the Fore st 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 SI P 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 wa nted additional text about the impact of Tennessee sources upon other Class I areas. Pe r the previous discussion under the DOI FLM concerns, TDEC-APC believes that it has addre ssed 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 co mmented 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 ar e 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 comme nts 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 commen ts, 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 BA RT, USEPA wanted to know more about Tennessee’s rationale in making its decisions and the specificity of what constituted BART for these sources. Language ha s been added to the SIP narrative to describethat process. EPA also had difficulty in managing the review of the documents in the initial prehearing draft like some of the FLMs and as prev iously mentioned, electronic links, page numbers and tables of contents for the appendices have be en added to improve the navigability of the SIP

for reviewers.

### 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 VIST AS science package that was funded and overseen in its development as an ad equate demonstration of the validity of the science and the interpretation of that science. Again, the FLMs participated in the process of developing natural condition valu es throughout the process and seem satisfied that the values selected for the Tennessee Class I areas are prop er. 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 pe rformance analysis and that has been provided in the second pre-hearing draft. That information is also pr ovided 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 $20 0 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 Industria l 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, Eastma n 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 th e 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

### 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 SE VIC, it supported their comments. Those will be

addressed below.

Bowater Newsprint filed comments recomme nding 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 th at the language in the first pre-hearing draft that mentioned the possib ility of additional control at Bowater might be required for reasons other than this first review of the regiona l 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 doc umentation 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 di scounted the role of smoke from wildland fires from its initial analys is of visibility impairing pollutants. SEVIC

made similar comments on the North Carolina re gional haze SIP (recall that Tennessee shares two Class I areas, Great Smoky Mountains Nationa l Park and Joyce Kilmer Wilderness Area with North Carolina). Tennessee c onsulted 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 litt le 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 Te nnessee regional haze SIP. Chapter 1200-3-8 is already a part of the Tennessee SIP for meeting particulate matter nationa l ambient air quality standards. Until evidence demonstrates that fugitive dust also impairs the timely attainment of the regional haze natural background goals, TDEC-A PC will not make it a part of the regional

haze SIP.

The following EPA c omments 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 Pollu tion Control Board act upon the approval of the regional haze SIP for submission to

USEPA.March 25, 2008 - Public Hearing Comment Summary And Agency Response ReportCommenterCommentTDEC-APC ResponseUSEPA:SIPNarrativeComment#1Executive Summary, Page iii: Add languageto discuss the 4 BARTsources that will becontrolled and add an affirmative declarationthat BART eligible sources exempted fromcontrol were found to not cause visibilityproblemsat any Class I areas.The agency agrees with this comment and has added text tothe Executive Summary to address this comment.USEPA:SIPNarrativeComment#2aPage 10: Section 2.3 ofthe Narrative refersthe reader to Appendix B for moreinformation on how the new IMPROVEequation was used to estimate naturalbackground conditions, yet there is noinformation to that effect in Appendix B.The information is alreadyprovided in the followingattachments:Appendix B-2 - Revised IMPROVE algorithmAppendix B-4 – Natural Background & Visibility GoalsAppendix G – ModelingResults & Supplemental Analysis(for GRSM)USEPA:SIPNarrativeComment#2bPage 10: A citation is needed in eithersection 2.1 or 2.3 that leads the reader to thelocation in the SIP where the identity of the20 percent best and worst days forTennessee Class I areas is declared.The citation to Appendix F-2 has been added to Section 2.3declaring the location of the20 percent best and worst daysfor Tennessee Class I areas.USEPA:SIPNarrativeComment#3Section 1.5, Page 6:Either reference theprocedures for future, continuing consultationwith the FLMs per 40 CFR 51.308(i) toSection 11, or describe them in more detail inSection 1.5A reference to Section 11 and additional text relative to FLMconsultation has been added to Section 1.5 .USEPA:SIPNarrativeComment#4Page 15, Figures 3.1-1 and 3.1-2 and similarfigures in Section 7.2.4 reference a “Method1 Prediction”, yet there is no explanation ofwhat that means in the narrative.An explanation of “Method 1 Prediction” has been added tothe figures and section mentioned in this EPA Comment.Method 1 Prediction means using EPA default guidance forestimating Natural Conditions atClass I areas is explainedin Appendix B-4 (page 31).CommenterCommentTDEC-APC ResponseUSEPA:SIPNarrativeComment#5Data Tables 7.2.3-1 and 7.2.3-2 do notmatch the data in Tables 5 and 6respectively of Appendix D.3The data have been updated toBase G4 (B&F) and alignedto match the Narrative and Appendix D.3USEPA:SIPNarrativeComment#6Section 7.5.3 pp 55-59: More explanationneeds to be provided on how Tennessee willestablish enforceable BART limits uponaffected sources – Discuss the role ofTennessee Chapter 1200-3-23 in applyingthese limits to sources.Chapter 1200-3-23 clearly authorizes BART visibilityprotection requirements to be imposed upon sources as apermit term. [See Rule 1200-3-23-.05]. The four TennesseeBART sources are also Part 70 sources. The procedures foradding BART limits established under the regional haze SIPto the permit as an “applicablerequirement” as that term isdefined under Part 70 are federal rules that Tennessee mustfollow. The SIP narrative contains BART limits for eachsource that, upon approval byEPA, will bepromptlyincorporated into the source’s Part 70 permit.In summary, Tennessee has theauthorityto establish BARTas a permit term under its Rule 1200-3-23-.05, and thedutyto add it into the BART source’s federally enforceable Part70 permit as a new applicable requirement under federallyapproved Tennessee Rule 1200-3-9-.02(11). Operatingpermits that set these BART limits in the interim until theyare incorporated into the Part 70 permits appear at AppendixL-12.USEPA:SIPNarrativeComment#6aSection 7.5.2: The BART de-listing ofWeyerhaeuser in Sullivan County needsadditional discussion/justification.Text justifying the delistingof Weyerhaeuser as a BARTsource has been added to Section 7.5.2.CommenterCommentTDEC-APC ResponseUSEPA:SIPNarrativeComment#6bSection 7.5.2 p. 52 - Holston ArmyAmmunition Plant’sexemption from BARTthrough permit limitations: A permit term isneeded to declare that any subsequentincrease in emissions at this facility abovethe BART emissions threshold will triggerBART.Construction Permit # 961638P was issued to the facility onFebruary 25, 2008 limiting the facility’s potential to emitvisibility impairing pollutants below the BART thresholds.TDEC understands the context of the comment and agreesto insert such language in the facility’s operating permit tothe extent that it is allowed in federal and state rules.USEPA:SIPNarrativeComment#7Page 52: TDEC declared that it did notevaluate emissions of VOC an ammonia forBART. That conflictswith statements madein Section 6.2 ofAppendix L (page L-15).The two statements should be reconciled.The SIP Narrative and AppendixL have been reconciled toreflect harmony in statementsrelative to VOC and ammoniawith respect to BART.USEPA:SIPNarrativeComment#8Section 7.8, Step 3, Page 69; Appendix H,Step 23, page H-54: An evaluation of the fourreasonable progress factors mustaccompany the State’s justification that theCAIR is sufficient for reasonable progress forsubject electric generating units during thefirst planning period.Additional text has been provided in the SIP narrative andAppendix H similar to the language employed by the state ofNorth Carolina.USEPA:SIPNarrativeComment#9Section 7.8, Step 4,page 69: A briefsummary of the rationale to support the onepercent threshold choice or a reference toSection 5.0 of Appendix H should beprovided in the SIP narrative.A reference to Section 5.0 ofAppendix H has been providedin the SIP narrative.USEPA:SIPNarrativeComment #10aIdentifying sources for reasonable progresscontrol – Step 4, page 69: Additionaljustification/explanation of how the use ofincorrect SO2 Emissions at Tate & Lyle(formerly A. E. Staley)justified exempting thefacility from the 4-factor analysis.Additional justification/explanation for Tate & Lyle has beenadded to the SIP narrative in this section.CommenterCommentTDEC-APC ResponseUSEPA:SIPNarrativeComment#10bIdentifying sources for reasonable progresscontrol – Step 4, page 69: Additionalinformation/ justification is needed for APACTN Harrison Construction relative to theemissions mischaracterization and why theemission unit is nolonger consideredsignificant.Additional justification/explanation for APAC-HarrisonConstruction has been added tothe SIP narrative in thissection.USEPA:SIPNarrativeComment#10cIdentifying sources for reasonable progresscontrol – Step 4, page 69: Additionalinformation/ justification is needed for theDOE Y-12 Plant relative to the emissionsreduction project and why the facility is nolonger considered significantAdditional justification/explanation for the DOE Y-12 Plantrepowering project has been added to the SIP narrative inthis section and also in appendix H narrative.USEPA:SIPNarrativeComment#10(d)Section 10, page 75: Tennessee shouldclarify what it is planning to do to addressMANE-VU’s request for non EGU emissionsreductionsClarifying language has been added to the SIP narrative toexplain Tennessee’s responseto MANE-VU’s call foradditional non EGU emission reductions.USEPA:SIPNarrativeComment #11Section 13, page 78: The state may wish toclarify that no non-BART sources weredocumented to impactother states’ Class Iareas.The requested language has been added to this section ofthe SIP narrative addressing non-BART units at BARTsources. Additionally, non BART TN sources impactingClass I areas outside of TN at1% contribution or more arealso addressed in Table 13.2 main SIP narrative.USEPA:SIPNarrativeComment#12Appendix D.6b: How will the sources listedas shut down in thissection result inenforceableemission reductions?Clarifying language has been added to this section ofAppendix D.USEPA:Appendix HComment a.General: Tennessee should declare whetheror not it agreed with INVISTA and Bowater’s4 factor analysis – noting any areas ofdisagreementClarifying language has been added to this section ofAppendix H Narrative.CommenterCommentTDEC-APC ResponseUSEPA:Appendix HComment b.Page H-57: Consider listing costeffectiveness for Bowaterto switch to lowersulfur (0.6%) coalClarifying language has been added to this section ofAppendix H Narrative.USEPAAppendix HComment cPage H-57: A state orfederally enforceableoperating permit should be imposed uponBowater to limit the remaining useful life ofthe boilers if it was a deciding factor inTennessee’s decision to not requirereasonable progress controls during thisreview period.Clarifying language has been added to this section ofAppendix H Narrative.USEPAAppendix HComment dPage H-61:Tennessee should justify whyINVISTA was not required to use a lowersulfur coal at the$1,225 per ton of SO2removed level.Clarifying language has been added to this section ofAppendix H Narrative.USEPA:Appendix IComment a.This Appendix does not discuss how theBARTmodeling files will be archived,maintained and made available by the Stateto EPA and the public.Clarifying language has been added to this section ofAppendix I. Appendix I header, page 2.USEPA:Appendix LComment a.Revised titles for the tables in Appendices L2, L-3, and L-10are recommended thatclarifies what the emission data representswith respect to BART eligibility or otheraspects of the BART program.Revised Titles were addressedfor Appendices L-2, L-3, andL.-10.CommenterCommentTDEC-APC ResponseUSEPA:Appendix LComment b.Section 4, p. L-10 : This section contains thediscussion regardinghow the 0.5 deciviewBART contribution threshold was chosen.The discussion contains many goodreferences to the BART guidelines andprovides a useful map of BART sources inthe VISTAS region. The last paragraph ofthis section presents TDEC-APC’sconclusion that the0.5 dv threshold isappropriate because there are a limitednumber of out-of-statesources that impactthe TN Class I Areas. This rationale shouldbe expanded to address the spatial locationof BART sources both in TN and outside theState. Looking at Figure 4-1, there do notappear to be any large clusters of sources,which would be expected to have a largecombined impact at a Class I area on anygiven day. A discussion of this nature wouldenhance the conclusion of selecting the 0.5dv threshold. A reference to the effect ofclusters of sources is included in Section7.5.2 of the SIP Narrative, but it would behelpful to provide a more detailed discussionof this issue in Appendix L.Clarifying language has been added to this section ofAppendix L Narrative.CommenterCommentTDEC-APC ResponseUSEPA:Appendix LComment c.Section 7.3, p. L-26 :The State may want toupdate the table numbering described in thenarrative for clarity. We believe narrativereferences to Tables 5-3 and 5-4 are meantto read 7-7 and 7-8. Similarly, on page L-29,it appears that Table 7-8 in the narrativefollowed by a Table numbered as 7-7 couldbe updated in both places as 7-9.Mentioned Tables were correctly numbered.USEPA:Appendix LComment d.There are a number ofareas in Appendix Lwhich are incomplete. The areas arehighlighted in yellow. Itis assumed that thesesections will be completed with theappropriate information prior to the Final SIPbeing submitted to EPA.Appendix L highlights were removed and reference toattachments were properly addressed.

## This section is reserved for the Pub lic 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 Secretar y 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 pr otect 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 th e 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 Conserva tion 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, 12 th Floor, 401 Church Street, Nashville TN 37243, (615) 532-0207. Hearing impaired callers may use the Tenne ssee Relay Service (1-800-848-0298).



### If you have any questions about the proposed PM 2.5 SIP, you may contact Mr. Travis Blake at (615) 532-0617. If you have any questions abou t 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, 9 th 

### Floor, L & C Annex, 401 Church Street, Nashville, TN 37243-1531, telephone (615)

532-0600.Summary of Proposed Change

The fine particulate matter (PM2.5) SIP for the Knoxville PM 2.5 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, andthe portion of Roane County that includes the Tennessee Valley Authority’s Kingston Fossil Plant, as nonattainment for the annual PM2.5 National Ambient Air Qua lity 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 subm it a State Implementation Plan (SIP) to EPA by April 5, 2008, that demonstrates progress toward attainment. Te nnessee proposes to demons trate in the SIP that the

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

and other evidence.

Air quality modeling conducted for Tennessee by the Associ ation 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 fo r 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 (NO X ) as a PM2.5 attainment plan precursor and evaluate sources of NO X emissions in the State for control meas ures, unless the State and EPA provide an appropriate technical demonstratio n for a specific area showing that NO X emissions from sources in the State do not significantly contribute to PM2.5 concentrations in th e non-attainment area. Tenne ssee is submitting two options

to address NO X as a PM2.5 attainment plan precursor, as follows:

1. The draft SIP contains a technical demonstration, which shows that NO X 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 NO X 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 NO X , or if Tennessee otherwise determines that the

State must address NO X 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 pl an measures to address NO X . The information contained in this addendum would become a Federally enforceable part of the SI P. If EPA approves Tennessee’s technical demonstrationfor NO X , or if Tennessee otherwise determines that the State is not required to address NO X 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 NO X 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 NO X as a PM2.5 attainment plan precursor.

Regional haze is fine particle pollution that impairs vi sibility over a large region including Class I areas such as national parks and wilderness areas. Sources of haze-formi ng 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 conditio ns 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 mon itoring strategy for measuring, ch aracterizing, 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 Te nnessee’s Regional Haze SIP. Numerous changes have been made to the original draft SIP, and the Division has elec ted 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 a nd 2018. States are required to evaluate progress every five year s to assure that emission contro ls 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 existi ng 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 pr oposed additions an d/or revisions will be availa ble for public inspection during normal working hours starting Februa ry 22, 2008, at the following locations:

HAir 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 Street711 R. S. Gass Blvd. Kingsport, TN 37660

Nashville, TN 37243

All persons interested in the air quality of the State of Te nnessee 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 Polluti on Control Board, 9th Floor L & C Annex, 401 Church Street, Nashville, Tennessee, 37243-1531.

D:/ln/MAR2008.doc