1 

### Vaupel, Claudia

From: Heil, Cynthia L (DEC) <cindy.heil@alaska.gov>

Sent: Friday, January 06, 2017 12:18 PM

To: Suzuki, Debra

Cc: Vaupel, Claudia; Spenillo, Justin Subject: Response to Clarification request for the FNSB Moderate SIP

Attachments: Final - clarification request 1.06.2017.docx

Debra, please find the response to your list of clarification questions. Please let me know if there is anything else we can provide. I should have another submittal to you here within the next hour or so (QM report).Response to Clarification Request January 6, 2017

Page 1 Update of the control measures: Summarize the updates that have been made to the control measures by the supplementary submittals. Provide a table that includes all of the control measures and the expected

emissions reductions from each measure. For each of the identified control measur es that were deemed technologically infeasible based on the Borough’s referendum prohibiting home heating regulation, please identify the measures that have since been adopted and submitted for EPA review. For measures that were not adopted and submitted f or review, ADEC must provide an explanation as to why the adoption of such control(s) is unreasonable. Explain the status of the contingency measures in relation to RACM.

DEC is providing an updated version of Table 5.7

- 6 i n response to your request for identification of measures that have been adopted into the SIP following the initial submittal of the moderate SIP . DEC revised the technological feasibility of control measures that had been initially identified as infeasible due to a Borough referendum, and provided an explanation of infeasibility of measures that were not adopted, and an explanation of the impact of contingency measure implementation on RACM

.

In the September 7, 2016 adoption, the SIP amendments incorporated eight ( 8 ) ordinances approv ed by the Fairbanks North Star Borough (FNSB) between February 2015 and August 2016. The SIP amendments were filed on October 27, 2016 and will be effective on November 26, 2016. Vol. III, Appendix III.D.5.7 of the

Moderate SIP contains the Reasonable Ava ilable Control Measure Analysis

. The modified Table 5.7

- 6 provide s context on how the programs and provisions within the new ordinances and regulations have changed the original analysis. Only those areas within Table 5.7

- 6 that have been impacted by the SIP amendments are shown below.

Modified Table 5.7

- 6 showing changes due to approved ordinances and regulations

Source Category Control Measure Techno

logically

Feasible? Revised

Technical Feasibility Clarification

Dry Wood

Measure Ban on green

wood sales No Addressed through

alternative

control

measures This measure is technologically infeasible but the State has

implemented alternative control measures.

The timing and volume of wood sales in the nonattainment area and

the land available for wood sellers to store and season wood makes a total ban on green wood sales technologically infeasible. The inability to handle and store large volumes of wood for se asoning is compounded by restrictions in accessing state and federal land for timber cutting. Areas are only open to cutting in the winter months when the ground is firm and chance of forest fire minimal.

Alternative control measures have been implemen ted by the Borough and State to address the use of green wood in the nonattainment area. State regulations require the use of dry wood during wintertime and limit opacity during air alerts. Borough Ordinances , adopted in February 27, 2015, require that only dry wood may be burned year round. A State wood moisture disclosure and recognized dry wood seller program has been implemented on a voluntary basis. Wood sellers will be required to register with the State in order to sell wood upon the area’s recla ssification to serious. Both the voluntary and mandatory programs assist consumers in understanding the moisture content of their wood to improve compliance with the requirements to only burn dry wood.

Regional Kiln No Addressed through

alternative Regional firewood drying kilns were considered as a control measure

to increase the commercial availability of dry wood in the original RACM analysis. The measure was categorized as technologically infeasible due, in part, to a low consum er demand for dry wood. AResponse to Clarification Request January 6, 2017

Page 2 Source Category Control Measure Techno

logically

Feasible? Revised

Technical Feasibility Clarification

control

measures ban on green wood sales , if feasible, would increase the demand for

dry wood.

A regional kiln measure envisions a centralized facility where commercial sellers and private individuals could deliver split wood for drying. The labor and transportation costs associated with use of

a regional facility would make the service unattractiv e or uneconomical. Additionally , the Borough completed an analysis of running a government

- operated kiln and determined it would be

uneconomical and interfere with private industry

.

DEC has not encountered an example of a regional kiln in a review

of implemented control measures throughout the country.

Since the submittal of the Moderate SIP, a participant in the voluntary moisture disclosure program, classified as a recognized dry wood seller, has independently constructed a private kiln and provide s dry wood to consumers

. T herefore, a source of dry wood that is split stored and covered is available to the public. During the

2015

- 2016 winter season, the recognized dry wood seller was unable to keep up with demand

. The seller has expanded his storage capacity for the 2016

- 2017 winter season.

Hydronic

Heaters Mandatory

curtailment on air quality advisory days No Yes This measure has been recategorized as technologically

feasible due to Borough adoption in February 27, 2015 and was adopted into the SIP on September 7, 2016.

See the Recent Measures Section below for discussion.

Ban new

installations No Addressed through

alternative

control

measure This measure is technologically infeasible but the state has

implemented alternative control measures.

Banning new installations is technologically infeasible for the following reasons: 1) due to arctic conditions, alternative sources of heat must be an available option to the public to protect health, life, and pr operty. Second it would prohibit change outs from older devices to newer devices that meet stringent State and Borough emission standards. Prohibiting changeouts conflicts with the device changeout measure. Change outs of older existing devices provide e mission reductions that subsume any emission increases resulting from

the installation of new devices in instances where a device had not been previously installed.

State and Borough regulations require new units to meet strict

emission standards. B oroug h setback requirements also significantly reduce the number and type of lots where a hydronic heating device may be installed. By prohibiting the installation of new hydronic heaters in portions of the nonattainment area, this measure subsumes a portion of the emission benefits that could be obtained through banning newResponse to Clarification Request January 6, 2017

Page 3 Source Category Control Measure Techno

logically

Feasible? Revised

Technical Feasibility Clarification

installations throughout the area with an outright ban on ne w installations.

Remove at time

of home sale † No Yes This measure has been recategorized as technologically

feasible due to Borough adoption in February 27, 2015

.

State regulations include a modified version of this control as

a contingency measure in the original SIP submission. It will be triggered upon the area’s reclassification by EPA to a

“ serious ” nonattainment area

. Uncertified devices will be required to be removed or replaced before property sale or

conveyance. ADEC has begun to impleme nt this program by contacting and educating the regulated community

, including real estate professionals and home inspectors. These individuals are likely already informing client s of the upcoming requirement, increasing likelihood of early compliance.

All units must

be certified No Addressed through

alternative

control

measure This measure has not been recategorized as technologically

feasible

, but it has been addressed through an alternative

control measure.

This measure would accelerate the turnover of uncertified devices. The Borough change out program already accelerates

turnover by facilitating change outs that may have otherwise

not occurred.

Borough code amendments, adopted May 4, 2016, also ha ve a
mechanism to accelerate turnover of uncertifi ed devices by requiring the removal of hydronic heaters that do not meet emission criteria after repeat code violations.

Resource priorities are focused on identifying and removing

the worst polluting hydronic heaters

.

Ban use No Addressed through

alternative

control

measure This measure has not been recategorized as technologically

feasible

, but has been addressed through an alternative control

measure.

Borough regulations adopted February 27, 2015 curtail solid fuel fired device use during Stage 2 and 3 air quality alerts

. This measure subsumes emission benefits that could be obtained through banning use at all times because it curtails use during pollution episodes.

Wood Stoves Mandatory

curtailm ent on air quality advisory days No Yes This measure has been recategorized as technologically

feasible due to Borough adoption February 27, 2015 and was adopted into the SIP on September 7, 2016.

See the Recent Measures Section below for discussion.Response to Clarification Request January 6, 2017

Page 4 Source Category Control Measure Techno

logically

Feasible? Revised

Technical Feasibility Clarification

Replace

uncertified

stoves at time of

home sale No Yes This measure has been recategorized as technologically

feasible due to its upcoming implementation as a contingency

measure

.

State regulations include this control as a contingency measure in the original SIP submission. It will be triggered upon the
area’s reclassification by EPA to “serious”. Uncertified devices will be required to be removed before property sale or

conveyance . ADEC has begun to implement this program by contacting and educating the regulated community, including real estate professionals and home inspectors

. These individuals are likely already informing clients of the upcoming requirement, increasing likelihood of early compliance. Initial contacts began in May 2016 with 1400

letters sent to real estate professionals in addition a dedicated webpage has been developed to provide information: http://dec. alaska.gov/air/anpms/comm/fbks_pm2

- 5_real

estate.htm

Replace

uncertified

devices at time of significant remodeling No Addressed through

alternative

control

measure This measure has not been recategorized as technologically

feasible but it has been addressed through an alternative

control measure. The FNSB does not have building code requirements

. T herefore there are no mechanism to monitor or

track remodels

. I t is economically infeasible to set up an entire building code program with inspectors only for identifying uncertified heating devices.

This measure would accelerate the turnover of uncertified

devices. However, t he Borough changeout program already

acc elerates turnover by facilitating change outs that may have

otherwise not occurred.

Resource priorities are focused on identifying and removing the worst pollut ing stoves

.

All units must

be certified No Addressed through

alternative

control

measure This measure has not been recategorized as technologically

feasible but it has been addressed through an alternative

control measure.

This measure would accelerate the turnover of uncertified devices. The Borough change out program already accelerates

turnover by facilitating change outs that may have otherwise

not occurred

.
Resource priorities are focused on identifying and removing the worst pollut ing stoves

.

Replace

uncertified

stoves in rental

units No Yes This measure has been recategorized as technologically

feasible due to its upcoming implementation as a contingency

measure

.Response to Clarification Request January 6, 2017

Page 5 Source Category Control Measure Techno

logically

Feasible? Revised

Technical Feasibility Clarification

State regulations inc lude this control as a contingency measure in the original SIP submission. It will be triggered upon the

area’s reclassification by EPA to “s erious”. Uncertified devices will be required to be removed before property lease. ADEC has begun to implement this program by contacting and educating the regulated community, including real estate professionals and rental property owners . These individ uals are likely already informing clients of the upcoming requirement, increasing likelihood of early compliance. Initial contacts began in May 2016 with 1400 letters sent to real estate professionals in addition a dedicated webpage has been developed to provide information: http://dec.alaska.gov/air/anpms/comm/fbks_pm2

- 5_real

estate.htm

Require

alternate heat

source in rental

units No This measure has not been recategorized as technologically

feasible.

The number of rental units containing solid fuel fired heating

devices as a sole source of heat is low and the benefits of this

measure are assumed to be small.

Resource priorities are focused on identifying and removing

worst polluting stoves

.

Require

alternate heat

source in new

construction † No Yes This measure w as adopted in Borough code July 28, 2016 . The

mechanism involves No Other Adequate Source of Heat ( NOASH ) waivers to curtailment actions. No properties constructed after December 31, 2016 will be eligible for a NOASH waiver, essentially requiring the residence to install

an alternative heat ing source to comply with curtailment

actions.

Ban new

installations No This measure is technologically infeasible because in extreme cold temperature it can be critical to have a supplemental heating source , especially one that does not rely on electricity, or risk damage from freezing up as well as back

- up heat if power fails. Resource priorities are being focused on identifying and removing the worst pollut ing stoves

.

Disincentive to

sell used stoves No Yes This measure has been recategorized as technologically feasible and updated State regulations were adopted into the SIP on September 7, 2016.

ADEC has clarified in its regulations that the emission standards for new installations also apply to reinstallation of

devices in the nonattainmen t area, prohibiting the installation

of used stoves.

The B orough change out program offers financial incentive to replace devices through the program or to turn in devices through a bounty program. It is a requirement that all used

devices must be turned in for destruction.Response to Clarification Request January 6, 2017

Page 6 Source Category Control Measure Techno

logically

Feasible? Revised

Technical Feasibility Clarification

Ban use No Addressed through

alternative

control

measure This measure has not been recategorized as technologically

infeasible but has been addressed through an alternative

control measure.

Borough regulations adopted February 27, 2015 curtail solid fuel fired device use during Stage 2 and 3 air quality alerts.

This measure subsumes emission benefits that could be obtained through banning use at all times because it curtails use during pollution episodes.

Use stove

ch ange outs to generate NSR

offsets No This measure has not been recategorized as technologically feasible and has not been addressed through an alternative

control measure.

This measure envisions companies providing incentive programs for stove change outs in exchange for emission offsets needed for new major industrial sources. Major industrial growth in the nonattainment area has been expected to be minimal and no projects have been identified that would take advantage of this type of measure for new source review ( NSR ) offset since the submission of the original moderate

SIP.

Fireplaces & Fireplace

Inserts Mandatory

curtailment on air quality advisory days No Yes This measure has been recategorized as technologically

feasible due to Borough adoption February 27, 2015 and was adopted into the SIP on September 7, 2016.

See the Recent Measures Section below for discussion.

Recent Measures Adopted into SIP (directly or by reference) on September 7, 2016

Recent

Measures Adopted Borough Programs

Mandatory

Curtailment during Episodes Yes The B orough episode program, adopted February 27, 2015

, adopted into SIP section III.D.5.11 on September 7, 2016, sets episode levels and requires mandatory curtailment of certain device types based on the severity of the episode.

Requirement to only burn dry wood year

round. Yes This Borough measure

, adopted February 27, 2015, requires that only dry wood be burned in a wood

- fired device. The effect is to give the Borough program an enforcement mechanism when responding to complaints where an individual may be burning wet wood.

Air Quality

Control Zo ne Yes Air quality zones allow the State and Borough the opportunity,

whe re appropriate, to focus resources and implement subarea

specific control measures t o address l ocalized air pollution

concerns.

Restricted Fuels

List Yes This Borough measure
, adopted February 27, 2015, restricts the types of fuels that may be burned in a solid fuel fired device. The effect is to give the B orough program an enforcement mechanism when responding to complaints where an individual may be burning materials that do not burn cleanly.Response to Clarification Request January 6, 2017

Page 7 Source Category Control Measure Techno

logically

Feasible? Revised

Technical Feasibility Clarification

Opacity † Yes B orough regulations adopted February 27, 2015 require solid

fuel heaters to comply with a 20% opacity limit regardless of whether an air quality alert is in effect

.

Emissions crossing property lines † Yes This control measure adopted February 27, 2015 limits the

amount of direct PM 2.5 emissions which are allowed to cross a property line. Concentrations of 25μg/m3 over normal neighborhood background are considered illegal inside of the

nonattainment area.

Hydronic Heater

Setback requirements † Yes This Borough measure adopted February 27, 2015 requires newly installed hydronic heaters to be located set minimum distances away from property lines and sensitive locations

. The effect of this measure is to limit the installation of hydronic heaters to large lots which are unlikely to exist in more densely populated areas. This also reduces the total number of properties where a hydronic heater may be

installed.

SFBA

req uirements limiting coal

installation † Yes This Borough measure
, adopted February 27, 2015, limits the types of solid fuel burning appliances (SFBA) that may be installed to those that meet emission standards as tested by a laboratory or other approved procedure. The effect of this measure is to ensure only clean burning devices are installed

in the nonattainment area. Devices must be EPA certified o r have been tested to meet the standards by an alternative

means. Due to the lack of an EPA standard and test method for coal devices, this measure has the effect of prohibit ing the installation of coal devices without undergoing independent

emission test ing.

Uncertified Hydronic Heater

Nuisance unit removal upon

2 nd conviction of

violation of opacity or property line crossing † Yes This Borough measure

, adopted May 4, 2016, requires

removal of proven gross pollut ing units

.

Nuisance provision † Yes This measure , adopted February 27, 2015, provides a dditional enforcement capability for B orough staff. Borough Chapter

Penalties † Yes Borough code adopted February 27, 2015 includes defined penalties for violations of requirements. These penalties are intended to increase compliance rates.

State Programs

Curtailment during Episodes Yes A state curtailment program that will only be implemented if the Borough is unable to implement its own program was adopted into the SIP September 7, 2015.

Moisture

Disclosure Program and Yes A State wood moisture disclosure and recognized dry wood seller program has been implemented on a voluntary basis. Wood sellers will be required to register with the State in order to sell wood uponResponse to Clarification Request January 6, 2017

Page 8 Source Category Control Measure Techno

logically

Feasible? Revised

Technical Feasibility Clarification

Wood Seller Registration the area’s reclassification to serious. Both the voluntary and mandatory programs assist consumers in understanding the moisture content of their wood to improve compliance with the requirements to only burn dry wood.

Prohibited Fuels

and Requirement to burn dry wood

October 1

– March 31 Yes This State measure was adopted into state regulation prior to

the initial submittal of the moderate SIP and was inadvertently excluded from the RACM analysis.

† Signifies measures adopted or found technologically feasible since the SIP was submitted for which emission benefits have not been explicitly quantified

.

As footnoted at the bottom of this modified Table 5.7

- 6, emission benefits were not separately quantified for

several measures i ncluded table that were adopted and implemented or found to be technologically feasible since the SIP was submitted. In general, although benefits from these measures are likely to increase over time

, they are expected to be small as of the required 2015 attainment deadline.

Control Strategy Summary Table

- Per the second element of your request, DEC is providing the following “SIP Control Strategy Reductions” table w hich summar i zes measure

- specific emission reductions in tons per day (tpd) and estimated concentration reductions (i n μg/m 3 ) for the comprehensive control strategy, which includes both original control measures from the SIP as well as measures implemented since the SIP submission

. Control

benefits benefits ( during episodic conditions) are shown where feasible, significant, and quantified. (Measures

not found to be feasible , were too small to quantify, or are addressed through alternative control measures are not listed in the table.)

The “Pre

- 2015” and “Pre and Post

- 2015” Control Measure Reduction columns delineate benefits through December 2014 (the submittal date) from reductions for measures implemented after the submittal but before December 31, 2015 (the required attainment date). The “2015

- 2017 RFP Reductions” column provides

estimated two

- year emission benefits (2015

- 2016) for all measures through the end of calendar year 2016 to

demonstr ate the additional reductions projected to occur before the first Reasonable Further Progress (RFP) milestone year (2017). All of the benefit estimates (except those under the “Voluntary Measures” category) are based on data collected by Alaska or the Bor ough through 2016 to date and represent permanent and enforceable

reductions.

To further distinguish 2015 measure benefits listed in the SIP versus those from measures adopted since its submittal, the “Control Measure” column includes parenthetical identi fications of “SIP” and “Clarification” to denote the origin of the benefit estimates, either the SIP or this clarification response.Response to Clarification Request January 6, 2017

Page 9 SIP Control Strategy Reductions

Control Measure Pre

- 2015

Control Measure

Reductions Pre and Post

- 2015

Control Measure

Reductions 2015

- 2017

RFP

Reductions (tpd) Implementation

Date (s) tpd μg/m 3 tpd μg/m 3

Voluntary Measures (SIP) :

- Mobile Sources †

- Other Sources †† PM 2.5 : 0.004

PM 2.5 : 0.055 0. 0 4

0.50 PM 2.5 : 0.004

PM 2.5 : 0.055 0. 0 4

0.50 ... . ...... ...... .. 2001

- 2015

Hydronic Heater Retrofits (SIP) PM 2.5 : 0.005 0.04 PM 2.5 : 0.005 0.04

... . ...... ...... .. 2012

Woodstove Change Out Program (SIP) PM 2.5 : 0.392

SO 2 :

- 0.014

NOx: 0.033

NH 3 : 0.014 3.06 PM 2.5 : 0. 392

SO 2 :

- 0.01 4

NOx: 0.03 3

NH 3 : 0.01 4 3. 0 6 PM 2.5 : 0.145

SO 2 : 0.000

NOx:

- 0.055

NH 3 : 0.002 06/2010

State W ood Device Standards (SIP ) n/a n/a n/a n/a PM 2.5 : 0.021

SO 2 :<0.001

NOx: 0.004

NH 3 : 0.001 2015

Dry Wood Measures (Clarification)

- State Moisture Disclosure

- State/Borough Dry Wood Programs n/a n/a PM 2.5 : 0.112

SO 2 : 0.004

NOx: 0.019

NH 3 : 0.004 1.10 PM 2.5 : 0.129

SO 2 : 0.005

NOx: 0.022

NH 3 : 0.005 Discl: 02/2015

DryWd: 02/2015

Borough Mandatory Curtailment Program (Clarification) n/a n/a PM 2.5 : 0.077

SO 2 :

- 0.006 0.73 PM 2.5 : 0.125

SO 2 :

- 0.009 03/2015

Energy Efficiency Measures (Clarification) PM 2.5 : <0.002 <0.02 PM 2.5 : <0.002 <0.02

... . ...... ...... .. 2008

Other, pre

- 2015 Requirements (18 AAC and Borough Code, Title 21):

- Opacity Limit

- Open Burning PM 2.5 : <0.001

PM 2.5 : <0.001 <0.01

<0.01 PM 2.5 : <0.001

PM 2.5 : < 0.001 <0.01

<0.01 ... . ...... ...... .. 02/2015

Other, post

- 2015 (setbacks, 2 nd conviction, no waivers for new buildings) n/a n/a PM 2.5 : <0.001 <0.01

... . ...... ...... .. 2015

- 2016

Vehicle/Device Turnover (SIP):

- Federal Motor Vehicle Control Program

- Uncertified Wood Device Turnover PM 2.5 : 0.135 ‡ 1.50 PM 2.5 : 0.135 ‡ 1.50

... . ...... ...... .. ... . ...... ...... ..

TOTALS PM 2.5 : 0. 5 91

SO 2 :

- 0.014

NOx: 0.033

NH 3 : 0.014 5.14 PM 2.5 : 0. 780

SO 2 :

- 0.01 6

NOx: 0.0 5 2

NH 3 : 0.0 18 6.97 PM 2.5 : 0. 42 0

SO 2 :

- 0.0 04

NOx:

- 0.0 33

NH 3 : 0.0 07

n/a

– Not applicable; these measures not yet implemented prior to 2015. † Voluntary mobile source measures include vehicle plug

- ins, walk/bike/carpool programs, increased transit bus ridership, and vehicle idle reduction programs. †† Voluntary other source measures include Solid Fuel Burning Device (SFBD) cessation alerts, public awareness education and improved SFBD operation (as noted in the SIP). ‡ Detailed mission breakdowns not available ; motor vehicle fleet turnover accounts for roughly 95% of reductions.

At your request, we have also included the “turnover” increment from the SIP at the bottom of the summary table to provide consistency with incremental reductions from the base year des ign value in the SIP (44.7 μg/m 3 ). This turnover increment reflects net reductions in emissions and modeled PM 2.5 concentrations due to motor vehicle fleet turnover effects from the federal Motor Vehicle Control Program as well as retirement

of old uncert ified woodstoves that has occurred (and continues to occur) outside the Wood Stove Change Out Program. Roughly 95% of these net reductions result from motor vehicle fleet turnover.Response to Clarification Request January 6, 2017

Page 10 Total emission reductions and estimated concentration reductions are show n at the bottom of the summary table.

The totaled reductions and incremental benefits shown were calculated in a manner that accounted for overlapping effects; thus the benefits reflect additive reductions with the effects of double

- counting removed.

The Voluntary Measures category includes the following elements:

Area Source Sector

 Voluntary Solid Fuel Burning Device ( SFBD ) Cessation

– alerts with multiple notification systems (email, text, social media, radio, TV, newspaper, etc.)

 Public awareness educ ation

– Split/Stack/Store/Save, sniffer maps, Take the Pledge program , annual maintenance, etc.

 Improved SFBD operation

– as noted in the SIP

Mobile/Transportation Sector

 Plug

- in

 Walk, bike, carpool

 MACS Transit bus

 Idle reduction

 Diesel idle reduction

Emission Reduction Calculation Methods and Data Sources

- 

### Following this summary table for additional

context, are brief category

- specific summaries of the emission benefits and the methods used to

calculate them for the recent measures adopted since the SIP was submitted

. Ben efits are calculated for the required 2015 attainment year unless otherwise noted. W he n the benefits of measure s overlap (for those quantified)

, the sum of the individual measure ’s benefits will be lower than achievable

emission reductions because one measure may impact the implementation and emission reduction potential of another measure when they are both operating together

.

An example of such overlap are individual emission benefits reported for the Wood Seller Registration/Moisture Disclosure Prog ram and the State program requiring only dry wood to be burned during the October 1 through

March 31 nonattainment season. Both measures reduce PM 2.5 emissions 1 by either educating (Moisture Disclosure) or mandating (Dry Wood Requirement) use of more dry wood than would occur in the absence of either measure. Since they both target the same source (in this case the amount of wet or “non

- dry” wood burned in the nonattainment area), their effects overlap each other. Thus summing their individually

- estimate d benefits will overstate combined reductions if both are applied.

Moisture Disclosure Program and Wood Seller Registration

– A “Wood Sales” database collected and maintained by DEC was used to estimate the effects of the Moisture Disclosure Program and Wood Seller Registration program on the average moisture level of wood burned for space heating during winter episodes

since t he program was implemented. The database contains records of commercial wood sales in the nonattainment area from October 2015 through September 2016 (a 12

- month period). For each record, the amount of wood sold is provided (in cords) along with either a moisture level estimate (from three measurements as required under the program) or a designation that the wood was sold wet or frozen. These data were analyzed to develop an estimate of the change in average wood moisture for commercially sold wood with these disclosure requirements in place. It was found that average moisture content for commercially sold wood dropped from 64% (based on average moisture of commercially sold wood from a 2011 CCHRC study) to 33 % based on analysis of the Wood Sales datab ase. This reduced the average moisture content for all wood

1 PM2.5 emissions decrease with lower moisture levels in wood. Stated simply, it takes more wet wood to provide a specific quantity of “effective” heat than dry wood since a portion of the combustion energy is used to evaporate the

moisture bound in the wo od.Response to Clarification Request January 6, 2017

Page 11 (including wood cut, split and stored by residents) from 36.4% to 3 0

. 3 %, which produced an estimated 4 .5 %

reduction in wood use and a reduction in PM 2.5 emissions of 0. 096 tons/day.

Prohibit Fuels and Requirement to Burn Dry Wood

– Using methods to translate changes in wood moisture content discussed elsewhere in the SIP and similar to those applied above, a separate estimate of PM 2.5 emission reduction was developed for the State program requiring only dry wood use during the winter nonattainment

season. Based on a DEC

- estimate of 10% initial compliance for the first year of the program , the average

wintertime wood moisture con tent would be further reduced to 29.3 % ( beyond the moisture reduction attained through commercially

- sold wood moisture disclosure ). This translates to a reduction in wood use of 0.7 % and a

PM 2.5 reduction for wood

- based space heating within the nonattainm ent area of 0.016 tons/day based in an initial year 10% compliance rate

.

Episodic SFBA Curtailment Program

– The Borough’s Solid Fuel Burning Appliance (SFBA) Curtailment Program requires mandatory cessation of combustion from solid

- fueled residential spa ce heating devices during Stage 2 and Stage 3 alerts called by the Borough under specific ambient air quality and temperature regimes

summarized as follows:

 Stage 2: 35 μg/m3 24

- hour PM 2.5 < 55 μg/m3

 Stage 3, ≥

- 15°F: 24

- hour PM 2.5 > 55 μg/m3 , ambient temperature , ≥

- 15°F

 Stage 3, <

- 15°F: 24

- hour PM 2.5 > 55 μg/m3 , ambient temperature , <

- 15°F

(The program also includes a Stage 1 voluntary component for which emission benefits were not analyzed.)

Under Stage 2, burning is permitted in al l EPA

- certified SFBAs, EPA Phase II qualified hydronic heaters with emission ratings of 2.5 g/hour or less, masonry heaters, pellet

- fueled appliances cook stoves and fireplaces. Burning is prohibited from all other devices including non EPA certified devi ces and waste oil devices.

Stage 3 includes separate restrictions depending on whether ambient temperatures are above or below

- 15°F (as measured in real time at the Fairbanks International Airport). Above

- 15°F, burning is prohibited in all SFBAs,

mason ry heaters, pellet

- fueled appliances, cook stoves, fireplaces and waste oil devices. When temperatures drop below

- 15°F, burning is permitted in EPA

- certified SFBAs, EPA Phase II qualified hydronic heaters with emission ratings of 2.5 g/hour or less, maso nry heaters and pellet

- fueled appliances. (Fireplaces are prohibited from operating under Stage 3 with temperatures ≤

- 15°F.)

The alert stages can be called for two separate air quality control zones (AQCZs) within the nonattainment area:

 Fairbanks (covering all of the nonattainment area except the Goldstream Valley and North Pole); and

 North Pole (the portion of the nonattainment area largely south and east of Badger Road).

Since the alert stages are AQCZ

- specific and occur under differen t ambient conditions, the first step in analyzing program benefits consisted of identifying the frequency of the days and average temperature conditions under which they occurred during calendar year 2015, separately for each stage and AQCZ. Tables

in the Temperature Exemption section show these alert stages frequencies. (The 182

- day nonattainment season runs from October 1 through March 31.) In 2015, Fairbanks alerts were based on the NCORE monitor, while

North Pole alerts were based on the North Pole F ire Station (NPFS) monitor.

Since daily space heating emissions are a function of the ambient temperature, the table below shows average daily temperatures associated with each alert stage and AQCZ. (Fairbanks had no Stage 3 days above

- 15 ° F in 2015). Baseline day

- specific emissions by device/fuel under this set of temperatures were extracted from the episodic emission inventory and these temperatures are shown in the following table

.Response to Clarification Request January 6, 2017

Page 12 Alert Condition Average Daily Temp (°F)

Fairbanks North Pole

Stage 2

- Days ≥ 35 μ g/m 3 and < 55 μ g/m 3

- 26.8

- 4.7

Stage 3

- Days ≥ 55 μ g/m 3 , Temp ≤

- 15 ° F

- 29.2

- 19.8
Stage 3

- Days ≥ 55 μ g/m 3 , Temp >

- 15 ° F n/a

- 0.4

Data collected by the Borough for operation of the curta ilment program in calendar year 2015 (its first year of implementation) were used to estimate the program’s compliance. The Borough developed a compliance rate estimate of 10% for the first year of operation (2015).

Next, emission reductions (at 1 0% compliance) were then calculate d for the day

- specific emission levels of each AQCZ (Fairbanks and North Pole) and alert stage (S2, S3>

- 15, S3<

- 15) by eliminating emissions from the specific devices and fuel for which burn restrictions occur under each stage. Logic was included to accou nt for emission increases associated with substitution of heating energy from curtailment restricted devices to a substitute device/fuel: a central oil furnace. Heating efficiency (as well as emission factor) differences between

each restricted device an d central oil were also accounted for. In addition to account for the “No Other Available Source of Heat” (NOASH) waiver provisions in the curtailment program, an estimate of NOASH households was developed from Fairbanks Home Heating Survey data. In the combined 2011

- 2015 surveys, it was found that 5.6% of surveyed households only had wood

- burning devices in the home; this percentage was used to estimate the fraction of potential NOASH households for which burn restrictions would be waived.

These emissio n calculations were performed separately for each AQCZ and accounted for the fact that the Goldstream Valley portion of the nonattainment area is not subject to these restrictions. (Goldstream Valley

emissions were scaled from the nonattainment area total based on occupied household counts from block

- level tabulations in the 2010 Census).

In the emission inventory (unlike for woodstoves and inserts), hydronic heaters were treated as a single source category weighted as 80% unqualified and 20% EPA Phase II qualified devices. To account for the fact that Phase II hydronic heaters with emission rates below 2.5 g/hour are allowed to operate during Stage 2 and Stage 3 (<

- 15 ° F) alerts, an estimate of the population of Phase II devices under 2.5 g/hour of 38% was developed from the list of Phase II qualified hydronic heaters from EPA’s “Burn Wise” database.

Using these inputs and assumptions, estimated average daily emission reductions on days of each alert stage for each AQCZ are shown below. Though not repo rted in the earlier Emissions Benefits table, emission impacts for

SO 2 are also shown. (The negative values represent the marginal increase in SO 2 emissions associated with substituting wood

- based heat with that from central oil.) Although North Pole has a higher fraction of wood

burning devices than Fairbanks, its average PM 2.5 emission reductions under each stage are lower because warmer temperatures can still trigger alert stages there as shown in the preceding table.

AQCZ Alert Stage Emission Reductions (10% Compliance)

PM 2.5 Reductions (tons/day) SO 2 Reductions (tons/day)

S tage 2 S tage 3

>

- 15 S tage 3

<

- 15 S tage 2 S tage 3

>

- 15 S tage 3

<

- 15

Fairbanks 0. 033 0 0. 062

- 0. 0 04 0

- 0. 0 04

North Pole 0. 021 0. 063 0. 043

- 0. 0 01

- 0.0 0 8

- 0.0 02

These reductions are specific to those days (and areas) for which alerts were called. Using the frequencies of each alert stage for each area based on 2015 monitoring and meteorology data, nonattainment episodic average daily reductions are shown below. (Again, negative numbers reflect emission increases.)Response to Clarification Request January 6, 2017

Page 13 Pollutant Episodic Average Daily Emission Reductions (tons/day)

With NOASH Waiver (10% Compliance)

Fairbanks North Pole Nonattainment Area

PM 2.5 0.039 0.038 0.077

SO 2

- 0.004

- 0.002

- 0.006

Regarding enforcement and resources for enforcement, Chapter III.D.5.11 of the Moderate SIP, Episode Plan

that was updated and adopted September 7, 2016 to include the FNSB ordinances has an expanded discussion on

enforcement and resources. Excerpts from the SIP chapter have been provided below.



### Ordinance 2015

- 01 grants the FNSB Air Quality Division the ability to r eceive, log, and investigate complaints as well as issue warnings and citations for verified violations of FNSB code. In June of 2015 the division added two complaint investigation and response staff members. These two postions utilize a mobile air quali ty monitoring vehicle (sniffer) to track

PM 2.5 

### concentrations in real time as well as a camera based opactiy reading service (EPA Method ALT 082) to verify air quality violations. Once verified, the staff members have the ability to engage the resident, d iscuss emissions reduction strategies, or issue mandatory warnings and citations in accordance with FNSB Code 21.28.030 and 1.20.080. Fines range from $100 to $1,000 depending on violation and number of offenses.

Property owners or managers may obtain a “No Other Adequate Source of Heat” (NOASH) waiver to episode burn cessation requirements if a property relies on a solid fuel

- fired heating device as its sole source of heat. To ensure no new construction occurs that would be eligible for a NOASH waiver

, Ordinance 2016

- 37 limits the waiver eligibility to properties constructed prior to December 31, 2016. NOASH applicants are urged to participate in the Borough change out program to help reduce emissions by installing an eligible wood or pellet

- fired

dev ice or replace a solid fuel

- fired device with a non solid

- fuel fired device.

On August 11, 2016, the assembly passed Ordinance 2016

- 20

- 1A to allow design and operation of a “low cost” air quality monitoring network in the Air Quality Control Zone. This

n etwork will be comprised, initially, of six Thermo Scientific pDR

- 1500 monitors and 20 MetOne Neighborhood monitors. A pDR

- 1500 network will monitor air quality throughout the Air Quality Control Zone and supplement regulatory monitor data when issuing adv isories and alerts and tracking air quality trends. A network of MetOne Neighborhood monitors will be used to locate and identify high

- emitting sources by deploying a small grid of monitors centered around “Hot Spot” areas identified by the “sniffer vehic le” or through complaints. Staff will investigate high

- emitting sources and seek compliance with regulations through education and will issue warnings or citations on a case

- by

- case basis. The MetOne monitors will be relocated to other hot spot areas in the Air Quality Control Zone as needed. Future operation of this air quality monitoring network is contingent on FNSB appropriations. This enforcement strategy will focus limited resources to areas that are most affected by poor air quality as identified through complaints, sniffer vehicle data, and other information. The ability to detect large emitters in nightime conditions with monitoring equipment will provide for more effective enforcement of the Borough episode program than visual detection of smo ke alone, especially when a smoke stack’s emissions are obscured or cannot be seen or photographed from a public right

- of

- way. Locating and engaging high

- polluting deviceResponse to Clarification Request January 6, 2017

Page 14 

### operators with enforcement efforts will provide greater emission reductions than trad itional program enforcement methods alone.

The two borough compliance staff will enforce the mandatory curtailment and other borough ordinances through; responding to complaints, driving the ‘sniffer’ vehicle daily and using the network of MetOne Neighborhood monitors once they are in place

. Resources at the Borough’s disposal are the two compliance employees that provide complaint response 7 days a week. The Borough also has two mobile vehicles that are

driven from 5:00 am

– 9:00 pm. One vehicle supports the hot spot program and the other vehicle is dedicated for complaint response. This is in addition to the MetOne monitors that will be deployed.

Effect on the impracticability demonstration : Explain the impact on the impracticability demonstration from the updated control measures in the supplementary submittals. Provide an analysis as to whether attainment would still have been impracticable had all of the measures been implemented earlier.

On October 8, 2014 a renewal of the citizen initiative limiting borough authority to implement solid fuel burning controls was defeated by local voters; the vote was certified by the Borough on October 23, 2014. Subsequent to the vote, the State had completed the proposed SIP and released it for public comment on November 14, 2014, with the expectation that the borough would implement SFBA’s (solid fuel burning appliance) control

measures. Given the holidays and time required to propose, notice and d ebate/agree on the selection of controls, ordinances for eight separate control measures were not passed by the Borough until February 2015. This sequence of events is entirely consistent with the Memorandum of Understanding (MOU) between the State of

Al aska and FNSB, where FNSB is the designated lead planning agency for the nonattainment area. Since measures are not effective without local support, it was/is appropriate for the borough to take the lead and follow its process in selecting controls. Prio r to and during this period, the State continued to provide education about the need for changes in behavior and options for reducing emissions. It would have been extremely difficult for the state to implement controls on a more expedited basis and if su ccessful, their implementation would have received much less public support and diminished compliance relative to borough implemented

measures.

Quantitative Analysis of Recent Measures

– To verify the findings of impracticable attainment by 2015, modeling results from the 2015 SIP Control inventory were re

- examined to assess whether the additional emission benefits from the measures adopted since the SIP submittal listed earlier would be sufficient to

demonstrate attainment across the entire PM 2.5 nonattainment area. Given the individual benefits shown earlier in the Emission Benefits table (which assumed 100% compliance or were based on reported compliance), an analysis was performed to combine the emission reductions from all rec ent measures and properly account for instances when individual measure benefits overlap (e.g. multiple types of dry wood programs). This analysis also incorporated realistic estimates of compliance rates for each measure in 2015 where actual compliance d ata were not available, reflecting initial but not fully

- realizable emission benefits as enforcement efficiency and compliance improves over time. Finally, the analysis utilized CMAQ results from the 2015 Control modeling to

translate these combined emiss ion benefits (in tons/day, averaged over the modeling episodes) to reductions in

24

- hour PM 2.5 concentrations across the nonattainment area. The analysis supports the finding of impracticable attainment by 2015, even after accounting for the benefits of recent measures implemented since the SIP was

submitted.

The following table summarizes the results of the recent measures analysis for the episodic conditions in the SIP. The 2015 Control inventory and modeling results upon which it is based already incorporated benefits

shown in the earlier Emission Benefits t able for subsidizing change outs of hydronic heaters, wo od stoves and fireplaces/inserts through continuation of the Borough’s WSCO program.Response to Clarification Request January 6, 2017

Page 15 2015 Attainment Analysis of Recent Measures

Measure Category PM 2.5 Emission Reductions Maximum

24

- Hour PM 2.5 Impacts (μg/m 3 ) Tons/day % of Inventory

State/Borough Dry Wood Measures (State Moisture Disclosure + State/Borough Dry Wood programs) 0.112 2.5% 1.10

Borough Mandatory Curtailment Program 0.077 1.7% 0.73

Energy Efficiency Measures <0.002 <0.05% <0.02

All Other Measures (including all inventory sectors) <0.001 <0.02% <0.01

TOTALS 0.192 4.4% 1.8 3

Estimated PM 2.5 emission reductions realized in 2015 (averaged over all episode days) from the recent measures are shown on both a tons/day basis as well as a percentage reduction in total inventory emissions (from 2015 Control levels). As stated earlier, the emission reductions estimates avoid double

- counting and account for overlap between measures where applicable. The measure order listed in the table (from top to bottom) acco unt for overlap with the preceding measure(s).

These emission reductions are based on actual data where available (e.g., the aforementioned Wood Moisture Disclosure database). As noted earlier, i nitial 2015 compliance rates of 10% were estimated for the State/Borough Dry Wood programs and the Borough Mandatory Curtailment program based on discussions with DEC and Borough staff responsible for program enforcement. The rightmost column shows calculated

maximum reductions in ambient 24

- hour PM 2.5 levels ac ross the entire nonattainment area for each measure category. These estimated concentration impacts were based on source elimination runs performed in conjunction with the 2015 Control attainment modeling and are corrected to monitor

- based “design value s pace” (i.e., they are not “raw” model concentration estimates).

As shown at the bottom of the table, the combined emission reductions of 0.192 tons/day represent an estimated

maximum reduction in 24

- hour PM 2. 5 concentration of 1.8 μg/m 3 . The 2015 Control modeling in the SIP (Table

5.8

- 12) resulted in a combined reduction from all measures of 5.14 μg/m 3 . Coupled with the reductions for the

recent measures shown above (and accounting for measure overlap) yields a total benefit of 6. 97 μg / m 3

. ( This combined benefit is consistent with that reported earlier in the SIP Control Strategy Reductions summary table.)

The attainment modeling in the SIP predicted a design value

- corrected concentration of 39.4 μg/m 3 in 2015 at the Fairbanks SOB monitor (as well as higher concentrations elsewhere across the nonattainment area). Subtracting the maximum impact of 1.8 μg/m 3 estimated from combining all recent measures results in an

estimated 24

- hour PM 2. 5 concentration of 37.8 μg/m 3 . This is still above the 35 μg/m 3 standard and thus supports the finding of impracticable attainment by 2015, even after accounting for the benefits of recent measures implemented since the SIP was submitted.

Furthe r analysis was conducted using the methods above to estimate the levels of compliance needed for the State/Borough Dry Wood requirements and the Borough Curtailment program. It was found that 40% or higher compliance for both measures would be required to demonstrate attainment in the nonattainment area (including unmonitored grid cell areas). Over time, compliance rates at these levels can be achieved through increased public awareness and adaptation as well as increased and more efficient program enforc ement.

Air Quality Trends in 2014 and 2015

– T h e SOB FRM data did show a clea n data year in 2014 and in 2015.

H owever, unmonitored grid cell analysis prepared for the M oderate SIP and the data from special purpose

monitors showed that other areas within the n onattainment area had values greater than the standard. In early 2015, EPA also determined that the North Pole Fire Station (NPFS) monitor would be designated a s a regulatoryResponse to Clarification Request January 6, 2017

Page 16 monitor. This North Pole monitor’s 2012

- 2014 design value was 139 μg/m3. Cl early, while the SOB FRM may have showed the possibility of reaching attainment in 2015, the rest of the monitoring data clearly shows that the impracticability determination of the Moderate SIP was correct.

Implications for Reasonable Further Progress (RFP)

– As discussed in Section III.D.5.6.5 of the SIP, Section 172(c)(2) of the CAA requires that plans for non

- attainment areas “shall require reasonable further progress” and include a “current inventory of actual emissions from all sources of relevant pollutants in such area ... to assure that the requirements of this part are met.” The goal of RFP is to achieve generally linear progress toward attainment (as opposed to deferring i mplementation of some measures until the end or projected

attainment date ). Calendar year 2017 was established as the year for which RFP must be demonstrated beyond the required attainment year of 2015 in the Moderate Area SIP. This sub

- section provides a brief assessment of the implications on RFP in 2017 when mea sures adopted since the SIP was submitted are accounted for, along with other updated control measure information. It focuses only on primary PM 2.5 since this was the only pollutant for which benefits were fully analyzed from these measures.

The quantitative milestone targets set in the SIP for the 2017 RFP year were 3.96 tons/day of PM 2.5 for the entire inventory within the nonattainment area. (This was linearly interpolated between the 2015 Control and 2019

Control inventories of 4.40 and 3 .52 tons/day, respectively.) Thus, average episodic emissions in the nonattainment area must be reduced from 4.40 tons/day in 2015 to 3.96 tons/day in 2017, a reduction of

0.44 tons/day. As discussed in the preceding sub

- section, the recent mea sures adopted since the SIP was submitted are estimated to provide a combined PM 2.5 emission reduction of 0.192 tons/day beyond the original 2015 Control inventory estimates. Based on initial compliance rates estimated for several key measures, this

combi ned benefit in 2015 is below the 2017 milestone target. However, compliance rates for these key Dry Wood Use and SFBA Curtailment measures are likely to increase over time and are expected to meet the milestone target by 2017 . DEC and the Borough will mo nitor compliance from these programs and update current benefits estimates to assess their greater benefit potential over time. This element, as well as other updated information (e.g. fuel switching implications for point source emissions from Flint Hill s Refinery shutdown and progress in natural gas expansion) will be examined in preparation of the RFP report required to be submitted to EPA within 90 days of the end of the RFP year (i.e. March 2018).

Fireplaces and certified devices during Stage 2 aler t s: Please clarify the rationale for allowing fireplaces

and certified wood

- heating devices to operate during a Stage 2 alert when ambient concentrations of

PM 2.5 exceed the NAAQS. Providing a comparison of the emissions to a program that includes these devices in the Stage 2 alert would be helpful. Explain how any impacts on the effectiveness of the curtailment program will be mitigated.

In February 2015, the FNSB Assembly established a solid

- fuel fired burning curtailment program for the first

t ime. The new program establishe d a framework to evaluate its effectiveness and allow adjustments over time. The program has three stages. Stage 1 asks for voluntary curtailment

. Stage 2 acknowledges those devices that

are EPA

- certified and allows continued burning

, but no un

- certified devices may be used. Stage 3 is a full

curtailment.

EPA

- Certified Devices:

The Stage 2 portion of the episode program requirements exempt EPA

- certified devices, EPA Phase II qualified hydronic heaters <2.5 g/hr, masonry heaters, pellet burning devices, fireplaces, and cook stoves. By exempting these devices during a Stage 2 alert, the Borough is calling attention to EPA

- certified devices an d demonstrating the benefits of installing lower

- emitting units. This assists in promoting use of the Borough’s change outResponse to Clarification Request January 6, 2017

Page 17 program. The benefits of this approach have been recognized in control programs implemented in other PM 2.5 nonattainment areas. 2

W hile certified devices may be exempt from curtailment during Stage 2, it should be noted that the opacity requirement and dry wood requirement are still in effect. Compliance staff will still address certified device use during a Stage 2 alert if there ar e opacity violations and emissions crossing property lines. Allowing certified devices during a Stage 2 is an educational tool that compliance personnel use when educat ing r esident s using a

non

- certified devices. This feature of the episode plan is import ant because it demonstrates the benefits of change

- outs to lower emitting heaters , which is a priority for the community

. It also provides an option for non

certified devices found in noncompliance. Replacing a non

- certified device with a cleaner burning device results in emissions benefits throughout the heating season. The emissions of properly operated certified devices are low in comparison to uncertified devices which are curtailed under a Stage 2 alert

.

Fireplaces:

Fireplaces include a mix ture of combustion components, including: no inserts, uncertified inserts, certified inserts (catalytic and non

- catalytic) and pellet inserts. Roughly 50% of the 1,210 fireplaces included in the 2015 emission inventory for the nonattainment area are estim ated to have no inserts. Since fireplaces without inserts are highly inefficient, their use in Fairbanks is largely limited to ornamental operation. Borough discussions with owners has found that roughly 95% of fireplaces without inserts are not used at all. Instead, most units are plugged with insulation and used as display centers. Thus, they are not viewed as contributing emissions during Stage 2 alerts. Two thirds of the remaining fireplaces have inserts that are EPA certified. For these reasons, fireplaces are not viewed as a significant source of emissions.

Fireplace operation must still meet the opacity requirements and property lines emission restrictions . The borough assembly is focusing its resources in identifying and addressing compliance when individuals are not operating their devices correctly.

The PM 2.5 Stage 2 alert day emissions reductions associated with 100% compliance with a current Stage 2 alert

i s 0.522 tpd in Fairbanks and 0.326 tpd in North Pole. If fireplaces were removed from the exemption, 0.837 tpd would be reduced in Fairbanks and 0.491 tpd reduced in North Pole. If fireplaces and EPA

- certified devices were removed from the exemption, meaning no devices could operate without a NOASH waiver, 1 .337 tpd would be reduced in Fairbanks and 0.765 tpd in North Pole. The potential emission reductions not realized during a Stage 2 alert due to the current exemption for EPA

- certified devices and fireplaces in Fairbanks are 0.500 tpd for EPA

- certified de vices and 0.315 tpd for fireplaces. In North Pole, unrealized emission reductions are 0.274 tpd for EPA

- certified devices and 0.165 tpd for fireplaces.

Alert Stage Zone Certified Devices Exempted Fireplaces Exempted PM 2.5 Reduction, tpd * at 100% Complia nce

2 Fairbanks X X 0.522

X 0.837

1.337

North Pole X X 0.326

X 0.491

0.765

2 For example, the San Joaquin Valley PM 2.5 nonattainment area wood burning curtailment program was amended in 2014 to include exemptions for EPA

- certified devices during air quality episodes. The program allows EPA

- certified woodstoves to burn at concentrations between 20 and 65 μg/m 3 when all ot her devices are prohibited from burning. To qualify for an exemption, the program requires registration and triennial inspection by a professional. The purpose of the exemption is to encourage change outs to EPA

- certified devices. Public survey results indicated that reducing the number

of no

- burn days by exempting devices during curtailment episodes would incentivize change outs

.Response to Clarification Request January 6, 2017

Page 18 * The emissions estimates of fireplaces based on home heating survey data used in the analysis above may be biased high and not representative of actual conditions in the nonattainment area during wintertime

conditions. Borough staff do not perceive fireplaces to be a significant contributor to PM 2.5 emissions in the

nonattainment area. Fireplaces are generally not used as heating sources during the wint er in conditions when a Stage 2 alert may occur. Fireplaces are inefficient heaters and create a passage for significant heat loss in the

home. Staff have observed many instances where the fireplace was rendered inoperable through the use of

insulation o r plywood during pre

- verification visits for the change out program. Survey data may instead represent wood usage during shoulder seasons that may have been incorrectly reported or interpreted as wintertime home heating. Staff reported that there were no complaints or enforcement cases against fireplace operators during the 2015

- 2016 winter. For these reasons, further examination of the significance of wintertime fireplace emissions will be performed in the development of the Serious SIP.

Temperature ex emption: Provide a rationale for the suspension of the mandatory curtailment program when temperatures reach

- 15 ° F and a justification for why this temperature was selected. Also, explain how the exemption impacts the effectiveness of the curtailment program. We request that you provide information about past PM 2.5 levels at the North Pole and Fairbanks monitors during days that are below

- 15 ° F including how many of those days had PM 2.5 levels above 35 μg/m 3 . Explain how impacts on the

effectiveness o f the curtailment program will be mitigated.

As mentioned above, the curtailment program established in February 2015 established an initial framework. During public testimony taken while the curtailment program was being considered, a temperature thres hold was proposed by the public and established in response to the public testimony received. The refore, the temperature threshold is a feature of the episode program recognizing the unique challenges faced by residents during periods of extreme cold. Re sidents use wood heating as a form of supplemental heat to maintain livable conditions and mitigate economic hardships associated with high heating costs. The threshold was selected by the Borough Assembly as warranted to provide a balance to heating cost s and to improve compliance rates.

Local survey data collected by DEC and the Borough support the establishment of this threshold and economic challenges faced by residents who lean toward more wood

- burning under colder temperatures. The 2013 Wood Tag telephone

- based survey randomly sampled 216 wood

- burning households within the nonattainment area. For those 196 households that had alternative heating sources in addition to their wood device (e.g. a central oil furnace), a series of questions were aske d related to their heating practices and reasons under colder temperatures. These questions and their responses are summarized below (counts are shown in parentheses):

 Do you always burn wood at colder temperatures as a secondary source of heat?

Yes = 62.2% (122), No = 37.8% (74)

 Why (for those answering “Yes” above)?

Need extra heat = 13.9% (14), To save money = 50.0% (61), Both = 32.0% (39)

 At what temperature do you burn wood (for those answering “Yes” above) ?

Average =

- 2.1°F, Median = 0°F, with 57% of responses above

- 15°F threshold

These survey results clearly reflect residents’ cost and supplemental heat

- driven concerns. Based on the heating energy model used to develop the space heating inventory, over 340,000 additional BTU/day are neededResponse to Clarification Request January 6, 2017

Page 19 to heat a typical 2,200 square foot home in Fairbanks at

- 30°F than at 0° F 3 , an increase in heating energy of over 40%. Assuming heating oil costs $3 per gallon, this 340,000 BTU increment would represent a cost increase of roughly $270 per household pe r month using oil, a significant additional expense for many residents.

The

- 15°F triggering threshold is also well below the average mean of

- 2.1 °F and median of 0°F when respondents of the survey indicated that they burned wood.

Stage 3 alerts are announced regardless of temperature to comply with Borough Code and provide information to the public about air quality conditions so they may take precautions to guard their health. If after a Stage 3 alert is called and the temperature drops, t he Borou gh does not announce that the temperature is below

- 15 degrees nor does it officially cancel the State 3 alert . It should also be noted, residents exempted under the threshold still must comply with other restrictions such as a 20% opacity limit and limi ts on emissions crossing property lines. Borough compliance staff still respond to complaints and conduct business as usual regardless of the temperature . Therefore, impacts to Stage 3 alert effectiveness are mitigated through the enforcement of other Borough Code requirements on high emitting devices such as an opacity requirement and limits on emissions crossing property lines.

Please see the Emissions Benefit table above for an estimate of emission impacts.

Historical publicly available 24

- hour a verage correlated BAM concentrations obtained through EPA’s Air Quality System were compared to publicly available daily minimum temperatures at the Fairbanks International Airport. The t ables below provide the requested information for the State Office B uilding, NCORE, and North Pole Fire Station BAM monitors during the years in which they operated. BAM monitoring was discontinued at the State Office Building in April 2013. BAM monitoring continues at the NCORE and North Pole Fire Station

Sites and is us ed for calling the curtailment Stages and advisories

.

Number of Days with 24

- hour average BAM concentrations > 55 μg/m 3

SOB NCORE NPFS

Year ≤

- 15 ° F >

- 15 ° F ≤

- 15 ° F >

- 15 ° F ≤

- 15 ° F >

- 15 ° F

2006 1 0

2007 1 0

2008 6 0

2009 2 0

2010 7 0

2011 3 0 0 0

2012 8 0 9 0

2013 0 0 1 0 21 7

2014 0 0 14 26

2015 3 0 23 8

Total 28 0 13 0 58 41

Number of Days with 24

- hour average BAM concentrations > 35 μg/m 3 and < 55 μg/m 3

SOB NCORE NPFS

Year ≤

- 15 ° F >

- 15 ° F ≤

- 15 ° F >

- 15 ° F ≤

- 15 ° F >

- 15 ° F

2006 17 4

2007 6 2

2008 11 9

2009 13 8

3 These temperatures were chosen at equidistant departures from the

- 15 ° F threshold to represent average conditions

below a nd above the threshold for the purpose of estimating incremental heating costs.Response to Clarification Request January 6, 2017

Page 20 2010 14 1

2011 18 4 4 1

2012 23 0 21 0

2013 8 1 9 0 5 12

2014 6 3 7 19

2015 12 0 10 10

Total 110 29 52 4 22 41

RACT analysis: Clarify whether all current controls were identified accurately in the RACT analysis. For example, table 1 (Appendix III.D.5.7

- 64) does not identify facilities with water injection for NOx control,

however in the SO 2 and PM 2.5 RACT analysis section some facilities were described as being equipped with water injection for NOx control. Also provide clarification on Alaska costs to support the explanation that control measure costs would be higher in Alaska. In particular, EPA doe s not agree that $1000/per ton is an adequate cost threshold for NOx controls

.

Thank you for pointing out some inconsistencies between our Appendix text and tables

. Table 1. Emission Units, located at major stationary sources, with actual emissions of P M 2.5 , or a precursor, greater than 5 TPY ( Appendix III.D.5

- 7

- 64) should have listed water injection as a current control on GT #3, a gas turbine at GVEA

North Pole. That table has been clarified and is below.

“ Table 1. Emission units, located at major stationary sources, with actual emissions of PM 2.5 , or a precursor, greater than 5 TPY. ”

Facility Source Source Category Unit Size a Actual Emissions b Current

Controls Proposed RACT PM 2.5 SO 2 NOx

Fort Wainwright Boiler 3 Coal

- fired

boiler 230 MMBtu/ hr 2 109 101 Baghouse Baghouse

Fort Wainwright Boiler 4 Coal

- fired

boiler 230 MMBtu/hr 2 101 99 Baghouse Baghouse

Fort Wainwright Boiler 5 Coal

- fired

boiler 230 MMBtu/hr 2 126 117 Baghouse Baghouse

Fort Wainwright Boiler 6 Coal

- fired

boiler 230 MMBtu/hr 1 87 91 Baghouse Baghouse

Fort Wainwright Boiler 7 Coal

- fired

boiler 230 MMBtu/hr 3 171 197 Baghouse Baghouse

Fort Wainwright Boiler 8 Coal

- fired

boiler 230 MMBtu/hr 2 122 168 Baghouse BaghouseResponse to Clarification Request January 6, 2017

Page 21 Aurora Energy,

Chena Boiler 1, 2,

3, 5 c Coal

- fired

boiler 5 MW each

(Boilers 1,2,3); 20 MW (Boiler 5) 7.81

(total) 838.9 (total) 792.7 (total) Baghouse Baghouse

North Pole Refinery H

- 2001

Crude

Heater Liquid Fuel

Fired Process

Heater 325.6 MMBtu/hr 5.1 3.3 62.0 Ultra low

NOx burners No additional

controls

North Pole Refinery H

- 241

Crude

Heater Liquid Fuel

Fired Process

Heater 120 MMBtu/hr 2.0 1.0 44.6 Note (d)

North Pole Refinery H

- 1001

Crude

Heater Liquid Fuel

Fired Process

Heater 62.5 MMBtu/hr 0.3 0.8 20.6 Note (d)

North Pole Refinery B

- 401

Steam

Generation Liquid Fuel

Fired Boiler 25 MMBtu/hr 0.3 0.1 11.8 Note (d)

North Pole

Power Plant Gas

Turbine #1 Gas Turbine 60.5 MW 15.5 42.3 50.3 Continued use of

HAGO

Gas

Turbine #2 Gas Turbine 60.5 MW 131 326 464 Continued use of

HAGO

GT #3 Gas Turbine 43 MW 16.8 1.86 367 Water injection Continued use of

naptha and LSR

Zehnder GT#1 Gas Turbine 16.05 39.83 54.3 Continued use of

HAGO

GT#2 Gas Turbine 10.77 25.73 36.4 Continued use of

HAGO

UofA,

Fairbanks Boiler #1 Coal

- fired

boiler 84.5 MMBtu/Hr 3.62 123.8 250 Baghouse Baghouse

Boiler #2 Coal

- fired

boiler 84.5 MMBtu/Hr 3.77 128.93 260 Baghouse Baghouse

Boiler #3 Dual Fuel

fired Boiler 180.9 MMBtu/Hr 2 17.7 5.72 Continued use of

No. 2 Distillate

NOTES:

a From each facility’s Title V Permit Application.

b Actual emissions are based on information submitted in by facility operators 2013 for operations in 2011. The information was requested by Alaska Department of Environmental Conservation to satisfy the require ment to prepare a statewide point

- source emission inventory (40 CFR 51.30). The inventory report has not been completed.

c Emissions shown for the Chena boilers, which share a common stack, are the combined emissions for all four boilers.

d No RACT determi ned for this source because the only pollutant above the threshold is NOx.

The $1000/per ton cost threshold in t he RACT analysis contained in the Moderate SIP reflects the information that DEC had at the time of submittal. Since submitting the Moderate S IP, DEC has been working on gathering

new information in preparation of developing the Serious SIP. In April 2015, DEC requested that all stationary sources greater than 70 tons/per year develop a BACT analysis. DEC has received preliminary Alaska specific cost estimates from various stationary sources and has provided that information in the table below (Appendix

III.D.5.7

- 70, Table 1).

F or the Serious SIP, DEC has done some initial modeling work for a major stationary source precursor demonstration for NOx as provided un d er the new PM 2.5 implement at ion rule. DEC is investigating the NOxResponse to Clarification Request January 6, 2017

Page 22 contribution in the formation of ammonium nitrate to PM 2.5 . Early findings using the 2015 projected baseline

from the Moderate SIP shows th at removing all NOx emissions from point sources reduces the ammoni um
nitrate at the State Office Building monitor by 0.3 μg/m3 and therefore NOx controls on point sources do not significantly reduce PM 2.5

. The analysis will need to be finalized for the Serious SIP using the new 2013

baseline before NOx controls can be eliminated in the context of BACT. We are supplying this information at

this time to provide context to the RACT analysis

. R egardless of the cost threshold, RACT controls for NOx would not significantly reduce PM 2.5 based on this preliminary precursor analysis. DEC intends to further

discuss the full major stationary source precursor analysis with EPA as development of the serious SIP

continues . These discussions will allow DEC to more fully develop its analysis, which it intends to submit in

accordance with the new PM 2.5 implement at ion rule along with the new Serious SIP.

“ Table 1 a . NOx Control Techniques a “ (For Clarity, the Table s are is separated into a. Coal Fired Boilers, b. Oil

Fired Boilers and c. Turbines)
( NA, is not applicable and that particular source does not have those types of units)

Source Category Control

Technique Cost

Effectiveness ($/ton of NOx removed) a,b Alaska so urce specific cost effectiveness ($/ton of NOx removed)

UAF f Aurora Doyon (FT WW) c

Coal

- Fired Boilers (and Dual Fuel

- Fired Boilers)

Industrial Boilers firing coal (stoker) Low NOx

burner $1,526 (<250

MMBtu/hr) NA $4,877 i Evaluated as good combustion practice and O2 trim technology already included

Coal and

Biomass

- fired

Boiler C oal

F luidized

B ed with

stage
combustion Not in original

RACT Already included

in new boiler h NA NA

Boiler firing

coal SCR $1,550 $28,425 $20,242 j $17,417

Boilers firing

coal SNCR $1,370 $10,192 $5080 (ID 5) $11,792 (ID1,2,3) Technologically

infeasible

Boilers firing

coal NSCR Not in original

RACT Technologically

infeasible g This technology did

not come up in their

RBLC search and

was not evaluated This technology did not

come up in their RBLC

search and was not

evaluated

a Data from EPA Menu of Control Options (Updated 4/12/2012). The values shown are the bottom of the range, if a range was provided.

b 2006 dollars

c Fort Wainwright Boilers 3

- 8

F draft BACT analysis submitted ahead of Serious Area designation, RBLC 10 years reviewed for NOx control technologies.

G not a rich burn design unitResponse to Clarification Request January 6, 2017

Page 23 h UAF Fairbanks Boiler EU ID 113

i Aurora 1,2 and 3, Unit 5 already has LNB

j Aurora EU ID 1,2,3 and 5 combined

Table 1b

. N O x Control Techniques for Oil Fired Boilers

Oil Fired Boilers

Source Category Control

Technique Cost

Effectiveness ($/ton of NOx removed) a,b UAF

Mid

- size dual

fired oil boilers SCR Not in original

RACT $8,416

Mid

- size dual

fired oil boilers SNCR Not in original

RACT Technologically

infeasible

Mid

- size dual

fired oil boilers LNB/FGR Not in original

RACT $3,634/($189,312

operational

restriction UAF EU 4)

Mid

- size dual

fired oil boilers Natural Gas Not in original

RACT Technologically

infeasible

a Data from EPA Menu of Control Options (Updated 4/12/2012). The values shown are the bottom of the range, if a range was provided.

b 2006 dollars

Table 1c

. N O x Control Techniques for Turbines a

Turbines e

Source Category Control

Technique Cost

Effectiveness ($/ton of NOx removed) a,b GVEA

- Zehner and

North Pole k

Turbines, oil

fired Water

Injection &

SCR $3,691 $ 3,200/ $12,800

Turbines, oil

fired Water

Injection $2,070 $ 2,000/ $7,800

a Data from EPA Menu of Control Options (Updated 4/12/2012). The values shown are the bottom of the range, if a range was provided.

b 2006 dollars

e North Pole Power Plant GT1

- 3; Zehnder GT 1

- 2.

k GVEA cost are PTE first and actual based emissions second, PTE $ are in draft form and not completed yet for

BACT

University Of Alaska, Fairbanks (UAF) The UAF source for the purpose of RACT

, evaluated the new large coal and biomass fired boiler and two

exist ing mid

- sized diesel fired and dual fuel fired boilers (duel fuel on the second boiler is diesel and natural gas capable) as part of their draft BACT analysis for the Serious SIP. In Table 1a, the coal fired unit at UAF has a
fluidized bed and not a stoker feed coal boil er and therefor NA (not applicable) as noted. T he large coal andResponse to Clarification Request January 6, 2017

Page 24 biomass fired boiler was evaluated for controls SCR, SNCR, LNB/OFA, FGR/Stage Combustion, CFB
(fluidized bed combustion) , low excess air and good combustion practices. The SCR and SNCR costs are listed in Table 1a. The LNB/OFA/FGR/CFB is already included in the proposed boiler and the following was stated for the CFB technology: “Upon closer review of the RBLC data, staged combustion technology is the only LNB technology that has been identified as NOX BACT for large CFB boilers. Only pulverized coal

boilers have used OAF and FGR for NOX emission control. The proposed CFB boiler design includes staged combustion with the primary air jets raising the coal and limestone to be above the boiler feed bed and with secondary air being injected above the fed bed through the walls of the boiler. As a result, staged combustion is available for the CFB boiler and will be the only version of LNB technology considered in this BACT anal ysis.”

The last control technology for the coal boiler is NSCR and is technology infeasible and the following clarifies

the reason: “The RBLC search discovered no applications of NSCR for large boilers since 2005. This result occurred because boilers op erate under conditions far more fuel

- lean (with excess oxygen) than required to support feasible application of this technology. The boiler is anticipated to have exhaust gas between 1,550 degrees F and 1,650 degrees F, which is well above the

recommended exhaust temperature range. Flue gas cooling would be required. The RBLC did not identify NSCR as a technology available to boilers of this size and design. NSCR is not an available control technology because the proposed large boiler is not of a rich

- burn design.”

In addition to the coal and biomass fired boiler, UAF has two mid

- size oil fired boilers, they are very close to the proposed cut of 5 TPY and were not included in the original RAC T.

, The table ha s been updated to include

these two units. The co sts are listed in Table 1b and the two technologically infeasible option clarifications for SNCR and natural gas are listed below:

“An RBLC search discovered no applications of SNCR for mid

- sized diesel or natural gas

- fired boilers since 2005. SNCR is exp ected to achieve 30 to 50 percent NO X control without LNB and 65 to 75 percent when operated with LNB according to the EPA fact sheet (EPA

- 452/F

- 03

- 031). Although no applications of SNCR for mid

- sized boilers could be identified, SNCR is an

available contr ol technology for the mid

- sized boilers.”

And

“EU ID 3 is not configured to burn natural gas. Because Fairbanks does not have a pipeline source, natural gas is not an available fuel for consideration for this boiler. During the times that

EU ID 4 is firing natural gas, operators have noticed a pressure loss in the natural gas supply. Operating both boilers on natural gas at the same time would only exacerbate this pressure loss unless the natural gas delivery system was to be changed. For the above re asons, switching to only fire natural gas as a control technology is not an available option for either EU ID 3 or 4.”

Doyon (Ft WW)

Doyon Utilities has six stoker fed coal fired boiler units evaluated for RACT. The costs for SCR are noted in

Table 1a. T he technologies that are infeasible SNCR are described below from their draft BACT analysis for the

Serious SIP:

“

... the outlet stack temperatures for EU IDs 1through 6 are, in general, between 300°F and

350°F, which is well below the recommended SNCR temperature range of 1 ,550°F toResponse to Clarification Request January 6, 2017

Page 25 1

, 950°F. A considerable amount of heat would be required to achieve the specified

temperature range, especially given the number of days on which subzero temperatures

occur at FWA. Generating energy for heating would require additional fuel combustion and

would result in additional emissions of direct PM 2.5 and PM 2.5 precursors. As noted above,

ammonia slip is anticipated with SNCR use, resulting in additiona l PM 2 .5 precursor emissions.

Ammonia is more toxic than NOx and is classified by EPA as a hazardous material.

Page 1

- 7 of the EPA Air Pollution Cost Control Manual [ Section 4, Chapter 1

, May 201 6)

states, "SNCR is not suitable for sources where the residence time is too short,

temperatures are too low, NOx concentrations are low, the reagent would contaminate the
product, or no suitable location exists for installing reagent injection ports." DU agrees

with EPA and has determined that SNCR is not a technically feasible control measure due

to the temperature differential of the stack gas as compared to the recommended NSCR
operating temperature range. ”

Aurora The Aurora source has four coal fired boilers that produce electricity and locally distributed steam. Units 1,2 and 3 have a grate stoker and a re equipped wit h conventional burners and unit 5 has a spreader stoker and a Low

NOx burner. The control costs are listed in Table 1a. NSCR was not evaluated by this source and did not come up in their RBLC data search.

Flint Hills
Please note, the table above has been modified to remove the li q uid fuel

- fired process heating units that were only at the Flint Hill Refinery. The Flint Hill Refinery is preparing for permanent shut down of the refinery and

the RACT/BACT process heating u nits are currently under contract for demolition

. The company is in the process of rescinding their title V permit in the next few weeks and those units were removed from the updated

table.

GVEA

The GVEA source has two locations, North Pole and Zehnder. Both source locations have turbines and the costs for controls are evaluated and listed in Table 1c. The low end of the range of costs were calculated using PTE emissions and high end of the co st w ere calculated using actual emissions.



## Initial Major Stationary Source Precursor Demonstration: NOx

Sierra Research

, on behalf of DEC

, employed photochemical grid modeling to demonstrate that oxides of nitrogen (NOx) emitted from major stationary sourc es within the Fairbanks North Star Borough 24

- hour PM 2.5 nonattainment area do not contribute significantly to PM 2.5 concentration exceedances at the State Office Building (SOB) monitor. The modeling framework was previously described in the Moderate SIP section 5.8.7.

In brief

, Sierra configured the Community Multiscale Air Quality (CMAQ) model version 4.7.1 with emissions processed through the Sparse Matrix Operator Kernel Emissions (SMOKE) model version 2.7.5b and meteorological data generated by the W eather Research Forecasting (WRF) model version 3.1 for two severeResponse to Clarification Request January 6, 2017

Page 26 PM 2.5 winter episodes. The two episodes represent conditions between January 23 rd

- February 10 th and

November 2 nd

– 17 th ; their selection is described in section 5.3 of the Moderate SIP.

The baseline 2015 emissions inventories with actual point source emissions served as the starting point for emissions for all sources in the precursor demonstration. The details of these inventories are described in the Moderate SIP section 5.6.3 and supp orting appendix. NOx emissions were removed from all major stationary sources in the inventory before reprocessing the point sources through SMOKE. CMAQ

- model simulations were conducted for both winter episodes and both emissions scenarios: 2015 baseline and 2015 baseline without point source NOx. The multi episode 24

- hour average PM 2.5 concentration was then calculated for all grid cells with the first two and last one day removed. Sierra calculated future design values (FDVs) for both the 2015 project ed baseline and the 2015 projected baseline without NOx from point sources using the Speciated Modeled Attainment Test (SMAT) methodology incorporating relative response factors (RRF). Per EPA guidance the changes in total PM 2.5 due to the changes in ammo nium nitrate portion of the PM 2.5 were determined while particle

- bound water impacts were not adjusted. Sierra found that the total PM 2.5 FDV for the SOB monitor is reduced by 0.3 μg/m 3 when comparing the 2015 baseline to the 2015 major stationary source NOx elimination run. As a result the impact of NOx from major stationary sources appear to be insignificant in terms of attaining the 24

- hour PM 2.5 National Ambient Air Quality Standard.



## Additional Comprehensive Precursor Demonstration Clarification: VO C

The Moderate SIP presents information in addressing VOC as a precursor based on the 2008 baseline modeling. DEC would like to further clarify that the 2015 contributions of VOC from all sources to the 24

- hour average

PM 2.5 at the SOB monitor grid cell are 0.007  g/m 3 . The VOC contribution to PM was determined through the
CMAQ

- model outputs averaged across all episode days. CMAQ tracks organic carbon that is contributed due to secondary organic aerosol formation. Since there is good performance for th e organic carbon component of

PM 2.5 determined for the baseline modeling there is a high confidence that this VOC contribution number is accurate and very small. The model configuration in this scenario matches the one described for the NOx Major

Stationa ry Source Precursor Demonstration 2015 baseline.



## Motor Vehicle Emission Budgets

Table 5.6

- 28 has been edited to remove unnecessary extraneous text.



### Table 5.6

- 1

Fairbanks Non

- Attainment Area Motor Vehicle Emission Budgets

Calendar Year Motor Vehicle Emission Budgets
(tons/day)

PM 2.5 NO x

2017 0.33 2.13