BOARD: 

Paul C. Aughtry, I11 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

BOARD: 

Henry C. Scott 

Steven G. Kisner 

Secretary C. Earl Hunter, Commissioner 

Promoting andprotecting the health ofthe public and the environment 

M. David Mitchell, MD 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

November 9,2009 

A. Stanley Meiburg, Acting Regional Administrator 

US EPA Region 4 

Atlanta Federal Center 

6 1 Forsyth Street, SW 

Atlanta, GA 30303-8909 

Re: South Carolina Regional Haze State Implementation Plan - Clarification 

Dear Mr. Meiburg: 

The South Carolina Department of Health & Environmental Control (Department) submitted its regional 

haze State Implementation Plan (SIP) package on December 21,2007. 

Subsequent to this submittal, the Department received a question from the United States Environmental 

Protection Agency (USEPA) Region 4 staff via electronic mail on June 1,2009 (Attachment 1). 

This question pertains to the Department's reasonable progress analysis as depicted in the methodology 

applied to Appendix H.2.b and H.2.c of the regional haze SIP. Specifically, Region 4 staff question why 

six emission units located at three South Carolina facilities (Alumax, Cogen South, and Showa Denka 

Carbon) whose SO2 emissions were identified as contributing to one percent or greater impact on 

visibility at Cape Romain were not evaluated for controls using the four reasonable progress factors. The 

Department's response/clarification to the regional haze SIP as submitted in December is outlined in 

Attachment 2. 

Should you have any further questions concerning South Carolina's regional haze SIP, please feel free to 

contact Maeve S.R Mason of my staff at (803) 898-2230 or masonmr~,dhec.sc.nov. 

I 

Robert W. King, Jr., P.E. 

Deputy Commissioner 

Environmental Quality Control 

ec: Myra C. Reece, Chief, Bureau of Air Quality, SCDHEC 

Renee G. Shealy, Assistant Bureau Chief, Bureau of Air Quality, SCDHEC 

Robert J. Brown, Jr., Director, Division of Air Planning, Development & 

Outreach, Bureau of Air Quality, SCDHEC 

John Glass, Manager, Modeling, Division of Emissions Evaluation and Support, 

Bureau of Air Quality, SCDHEC 

Maeve S.R. Mason, Manager, Regulation Development, Division of Air Planning, Development 

& Outreach, Bureau of Air Quality, SCDHEC 

Attachment 1 : EPA Region 4 electronic mail transmission (June 1,2009) 

Attachment 2: The Department's response to questions on its regional haze SIP (December 2 1,2007) 

SOUTH CARO1,INA DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 
From: <Ward.Nacosta@epamail.epa.gov> 

To: <hollisao@dhec.sc.gov~, <flynntj@dhec.sc.gov>, <loftonat@dhec.sc.gov~ 

CC: <masonmr@dhec.sc.gov>, <Farngalo.Zuri@epamail.epa.gov>, <Benjamin.Lynora ... Date: 6/1/2009 1 1 :05 AM 

Subject: Training Opportunities - Notes from 5120109 Call 

Good Day All, 

*Please pass this on to Brian* 

This is a follow-up to the conference call that we held on 512012009. 

The main outcome of the call was the desire from DHEC for various 

trainings. In addition to training updates, I have also included the 

notes on Regional Haze from Michele. 

TRAINING 

Conformity Training 

Mike Roberts of the FHWA staff has been in contact with Melinda Mathias 

of your staff and plans to do a training in Columbia, SC on June 25, 

2009. For more information, contact Mike Roberts 404-562-3928. 

Source Apportionment Modeling Training 

No specific training is planned at this time. We are checking with 

OAQPS to follow-up on any potential planned briefings or trainings to 

state and local agencies. 

STAQS - August (Webinar~Webcast of the Summit?) 

Right now, webcastinglwebinar is not set up for this conference. 

REGIONAL HAZE 

Update: Staff has begun drafting the Federal Register on SC's Regional 

Haze SIP. The Region's original timetable for publishing these actions 

has slowed somewhat due to impacts of the CAIR remand on processing 

these SIPS. As discussed on previous calls with SC and the other 

States, the Agency continues to discuss options for acting on Regional 

Haze SIPS that rely on CAIR, in light of the CAIR remand and that CAIR 

will be revamped in the next few years along with changes in the SO2 

allowance market. No decisions will be made until the new 

Administration has been briefed on this issue. EPA Headquarters is 

currently updating model runs for where CAIR emissions reductions are 

anticipated to occur in light of changing conditions in the SO2 

allowance trading market due to the CAIR remand. We will continue to 

keep States informed on this issue. 

Question: We can use the State's help to answer a question related to 

its reasonable progress analysis. Specifically, using the State's 

reasonable progress area of influence methodology, all SO2 emission 

units with a 1% or greater impact on visibility at Cape Romain would be 

evaluated for control using the four reasonable progress factors. The 

following six emission units located at three SC facilities (Alumax, 

Showa Denko Carbon, and Cogen South) are listed as having a greater than 

1% impact according to the VISTAS spreadsheet in Appendix H.2.b of the 

SC Regional Haze SIP - Clarijication 

Attachment I 

November 9, 2009 
SC Regional Haze SIP. We could not find these six units discussed 

anywhere else in the SIP or any reasons for excluding them from further 

analysis. Could the State please explain its thinking related to these 

units? 

COGEN SOUTH ( OCA ( Electric and Other Services ( .02030 

I 1 Combined 3 

------------------------------+--------+--------------------------------+--------- 

ALUMAX OF SOUTH CAROLINA 1 002 ( Primary Production of ( 0.017 

( 1 Aluminum 1 

------------------------------+--------+--------------------------------+--------- 

ALUMAX OF SOUTH CAROLINA 1 003 ( Primary Production of ( 0.01 69 

( ( Aluminum 5 

------------------------------+--------+--------------------------------+--------- 

ALUMAX OF SOUTH CAROLINA 1 005 ( Primary Production of 1 0.01 69 

I I Aluminum 3 

------------------------------+--------+--------------------------------+--------- 

ALUMAX OF SOUTH CAROLINA 1 004 1 Primary Production of ( 0.01 50 

1 ( Aluminum 8 

------------------------------+--------+--------------------------------+--------- 

SHOWA DENKO CARBON 1 007 1 Carbon and Graphite Products 1 0.0141 

I I 7 

If there are additional points of interest that you were looking for 

follow-up on, please let me know. 

Have a wonderful day! 

Nacosta C. Ward, Environmental Scientist 

U. S. Environmental Protection Agency, Region 4 

Air, Pesticides & Toxics Management Division 

Air Planning Brancmegulatory Development Section 

6 1 Forsyth Street, SW 

Atlanta, GA 30303-8960 

email: ward.nacosta@epa.gov 

telephone: (404) 562-9 140 

facsimile: (404) 562-90 19 

SC Regional Haze SIP - Clarijication 

Attachment I 

November 9, 2009 
The South Carolina Department of Health and Environmental Condrol's 

Response to questions on it regional haze State Implementation Plan (Decedber 21,2007) 

Below is the South Carolina Department of Health and Environmental Control, Bureaul of Air Quality's 

(Department) response to questions on its regional haze State Implementation Plan (sI*) submittal. The 

discussion below addresses questions that were received by the United States Environqental Protection 

Agency's (USEPA) Region 4 staff in an electronic mail correspondence on June 1,20019, which sought 

clarification on the Department's rationale regarding its reasonable further progress analysis (four factor 

analysis). Region 4 staff specifically questioned why six emission units located at thre$ South Carolina 

facilities (Alumax, Cogen South, and Showa Denka Carbon) whose SO2 emissions conbibuted to 1 

percent or greater impact on visibility at Cape Romain (Appendix H.2.b) were not eval ated for controls 

using the four reasonable progress factors. The Department's response regarding the s'x units at the three 

facilities is outlined below. 

7 

Background: 

Using meteorological back trajectories, extinction-weighted residence time plots, and emissions 

inventories to identify the specific point sources of SO2 that were likely to be major contributors to 

visibility impairment at Cape Romain, the Department identified the specific geographic area that most 

likely influences visibility at Cape Romain (know as the area's SO2 area of influence [AOI]). 

As stated in section 1.3 of the SIP narrative, the Department then identified emission reductions that have 

already occurred or will occur by 20 18 within each source category or at specific units (to include other 

CAA programs, any BART requirements, and by measures in each State's long term strategy). 

In conducting the reasonable further progress analysis associated with the regional haze SIP, the 

Department calculated the fractional contribution from all emission units within the SO2 

A01 for Cape Romain and identified those emission units with a contribution of 0.0 1 or above (or greater 

than or equal to one percent contribution) to the visibility impairment at Cape Romain. The Department 

chose to adopt one percent as the contribution threshold used to consider a source for four factor analysis 

of reasonable further controls based on precedence established in other Federal programs. 

Each emission unit identified as having a contribution greater than or equal to one percent was evaluated 

using the statutory and regulatory factors of: (1) cost of compliance, (2) time necessary for compliance, 

(3) the energy and non-air quality environmental impacts of compliance, and (4) the remaining useful life 

of the emissions unit. 

For the purpose of evaluating the cost for the reasonable progress assessment, the Department believes it 

was not equitable to require non-EGUs to bear a greater economic burden than EGUs for a given control 

strategy. In determining reasonable costs of controls for the EGU sector, the Department determined that 

the cost of SO2 controls (the primary contributor to visibility impairment in the state) beyond those 

required by CAIR are not reasonable. These capital and operating unit-by-unit costs ranged from about 

$91 2 to $1,922 dollars per ton of SO2 removed; with an average cost per system ranging from $1,23 1 to 

$1,375 dollars per ton of SO2 removed (Appendix H.2.a). Therefore, $2,000.00 per ton was selected as 

the threshold for costs for non-EGU sources. The Department used this cost of compliance threshold as a 

screening tool to determine the universe of sources to perform the full four-factor evaluation. 

On behalf of its members, VISTAS employed a contractor to perform additional analysis of "every 

available SOz control strategy in AirControlNET against the EGU and non-EGU point source inventories 

to develop a master list of available, incremental control strategies" (Appendix H, page 44). Where 

SC Regional Haze SIP - Clarification 

Attachment 2 

November 9, 2009 
appendix H.2.c lists "VISTAS base case," it was determined that no potential controls here suggested for 

the particular unit(s). As depicted in appendix H.2.c, this is the case for unit 007 at Showa Denko Carbon 

and unit OCA at Cogen South (no controls suggested for these units). Units 002, 003, 004, and 005 at 

Alumax of South Carolina were identified as having one potential control option (Flue-gas 

desulfurization); however, the cost associated with this control option was estimated ad $35,404per ton of 

SOZ removed; well above the $2,000 cost threshold established. 

Only those units identified in the SIP narrative on page 100 and in Table 8.0-2 (represepting those sources 

identified as having a potential cost associated with fuel switching below the $2,000 tweshold 

established) were asked to conduct a four factor analysis to evaluate the potential costsassociated with 

fuel switching (see Appendix H, section 6.2.1 for more information). 

Conclusions: 

While each of the six units at the three facilities asked about in the aforementioned eledtronic mail 

correspondence (Cogen South, Showa Denka, and Alumax) were found to contribute one percent or 

greater to the visibility impairment at Cape ~omain,' they were not asked to conduct a four factor analysis 

based on the fact that no addition controls were identified as feasible and/or cost effective. Ths 

information was depicted in appendix H.2.c of the regional haze SIP submittal. 

The Department believes that it addressed this concern within the existing regional haze SIP submittal 

that was submitted on December 2 1, 2007, and that this documentation is provided to clarify the issue. 

' All sources with a Qld greater than or equal to five and an RTmax greater than or equal to 10 

percent were added to the list for further consideration because it has been determined that these 

sources may contribute to visibility impairment on the 20 percent worst days. I 

SC Regional Haze SIP - Clarrfication 

Attachnient 2 

November 9, 2009