MI" 

ee Freeman 

April 13, 201 1 

Gwen Keyes Fleming 

Regional Administrator 

USEPA Region 4 

Atlanta Federal Center 

6 1 Forsyth Street, SW 

Atlanta, GA 30303-8960 

Dear Ms. Fleming: 

I am pleased to submit the Section 1 lO(a)(l) Maintenance Plan for the 1997 8-Hour Ozone 

Standard for GreensboroNinston-SalemiHigh Point 1-Hour Ozone Maintenance Area. Enclosed 

is one hard copy of the complete package containing the Section 1 lO(a)(l) maintenance plan, as 

well as the supporting documentation as to how the emission estimates were developed and an 

exact duplicate electronic copy on compact disk. Additionally, the disk includes the MOVES 

model input and output files. 

The opportunity to request a public hearing, in accordance with 40 CFR 5 1.102, and the 

public comment period were noticed in the local newspapers on Wednesday March 2, 201 1. The 

public comment period was open from Wednesday, March 2,201 1 through Friday, April 1,201 1. 

There were no written requests for a public hearing and the only comments received were from the 

USEPA. 

In addition to addressing the USEPA's comments on the pre-hearing draft submittal, a few 

additional changes were made in the final submittal. First an error was found in the point source 

documentation. Some facility emissions were reported in pounds per year and had not been 

properly converted to tons in the pre-hearing draft. Additionally, other essors were discovered in 

converting the annual emissions to typical ozone season weekday emissions. These errors have 

been corrected in the final submittal. The on-road mobile source emissions were revised to reflect 

the revised MOVES2010a mobile model. The emission changes between MOVES2010 and 

MOVES20 10a were very minor. The area source emissions inventory was revised for the open 

burning of municipal waste and small stationary combustion sources. In the pre-hearing draft the 

open burning of m~~nicipal waste emissions were not adjusted to account for the NCDAQ's Open 

Burning rule 15A NCAC 2D .1900. The emissions have been adjusted similarly to how the 

emissions for this source category were adjusted in the fine particulate matter redesignation 

demonstration and maintenance plan submitted in December 2009. For the small stationary 

combustion sources, the methodology was revised to reflect the current USEPA methodology. 

1641 Mail Service Center, Raleigh, North Carolina 27699-1641 

2728 Capital Blvd., Raleigh, NC 27604 

Phone: 91 9-733-3340 I FAX 91 9-71 5-71 75 1 Internet: www.ncair.org 

An Equal OpportunityIAffirmative Action Employer 
Ms. Fleming 

April 13, 20 1 1 

Page 2 

Although the emission estimates presented in the pre-hearing draft have changed 

significantly in this final submittal, the overall message of the Triad I lO(a)(l) maintenance plan 

has not changed; the emissions in the future years are lower than the base year and continued 

maintenance is demonstrated. 

I respectfully request that you commence the federal approval process for the Section 

1 lO(a)(l) Maintenance Plan for the 1997 8-Hour Ozone Standard for CreensboroNiiinstonSalemJHigh Point 1-Hour Ozone Maintenance Area. If you should have any questions, please 

contact Laura Boothe of my staff at (919) 733-1488 or laura.boothe@ncdenr.gov. 

la C. Holman 

Attachment 

cc: Michael Abraczinskas 

Laura Boothe 

Dick Schutt 

Lynorae Benjamin